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 -----------------------------x

 PUBLIC MEETING FOR THE

 POLYCHLORINATED BIPHENYLS

 (PCBs): REASSESSMENT OF USE

 AUTHORIZATIONS ADVANCED

 NOTICE OF PROPOSED RULEMAKING

 -----------------------------x

 DATE: Tuesday, May 4, 2010

 TIME: 1:00 p.m.

 Taken at US EPA REGION 2, 290 BROADWAY,

 27th Floor, Room 2735 (Conference Room A), by

 Elizabeth Willeski, RPR, of Capital Reporting

 Company, a Notary Public in and of the State of

 New York.
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1 A P P E A R A N C E S:

2 QUANTECH, INC.

DAEMIAN SCHREIBER

3 2020 14th Street W, Suite 560

Arlington, Virginia 22201

4 (703)312-7831

5 SPEAKERS:

6 Dan Craft, Acting Chief, Pesticides and Toxic

7 Substances Branch Division of Enforcement and

8 Compliance Assistance U.S. EPA Region 2

9

10 Tom Simons, Environmental Protection Specialist,

11 Fibers and Organics Branch National Program

12 Chemicals Division Office of Chemical Safety and

13 Pollution Prevention, U.S. EPA

14

15 Jim Roewer, Executive Director, USWAG

16

17 Mary Davis, Principal Environmental Specialist,

18 American Electric Power

19

20 Aurelia Greene, Deputy Bronx Borough President

21

22 Jonathan Davis, NYS Assembly, Linda Rosenthal

23

24 Valerie Watnick, Associate Professor, Baruch College/City

25 University of New York, Zicklin School of Business
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1 A P P E A R A N C E S - continued:

2

3 Miranda Massey, New York Lawyers for the Public Interest

4

5 Patricia Donegan, Parent

6

7 Ann Casey, PCB Chemist, Northeast Analytical, Inc.

8

9 George Weymouth, Retired Waterproofer

10

11 Gigi Gazon, New York City PCB Free Schools Coalition

12

13 Daniel Lefkowitz, Private Citizen

14

15 Richard Barr, Chair of External Affairs Committee

16 for Occupational Safety & Health

17

18 Maureen LaMar, New York Committee for Occupational

19 Safety & Health

20

21 Mark Drozdov, Past President American Industrial

22 Hygiene Association

23

24 Charles Kellogg, Chairman/CFO Hubbard Hall

25 * * * * *
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1 PROCEEDINGS

2 MR. CRAFT: My name is Dan Craft. I'm the

3 Acting Chief of the Pesticides and Toxic Substance

4 Branch Division of Enforcement and Compliance

5 Assistance, US EPA Region 2. I'm joined this afternoon

6 by Maria Doa, who is the director of the National

7 Program Chemicals Division, and Tom Simons, who is the

8 Environmental Protection Specialist, Fibers and

9 Organics Branch in the EPA's Office of Chemical Safety

10 and Pollution Prevention. Welcome to our first of four

11 public meetings to gather comments on the issue of

12 EPA's reassessment of its current authorizations for

13 PCB use and distribution in commerce. We are planning

14 a -- we're considering a fifth meeting on the west

15 coast later on in the year. EPA had issued an Advanced

16 Notice of Proposed Rulemaking on April 7th, 2010,

17 initiating the agency's potential reassessment of PCB

18 use authorizations. We would like to thank you for

19 joining us today, and we very much appreciate you

20 taking the time this afternoon to assist us by

21 providing valuable on the state of the environment

22 regarding PCBs in use.

23 Now, it has been 30 years since their limited

24 uses were authorized. The purpose of this meeting is

25 to provide an opportunity for the public to present
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1 comments, information, and data regarding the Advanced

2 Notice of Proposed Rulemaking. EPA representatives

3 will be available to answer clarifying questions on the

4 comments of the April 7th Federal Register notice. In

5 addition to the comments received at today's meeting

6 and the remaining public meetings, EPA will also be

7 providing or accepting written public comments through

8 July 6th, 2010. You may provide those comments via

9 Docket Number EPA-HQ-OPPT-2009- 0757. Don't worry, we

10 have a handout that provides all these links for you,

11 and through regulations.gov or you may mail or hand

12 deliver them to EPA headquarters in Washington at the

13 address as listed in the April 7th Federal Register. We

14 encourage you to submit written comments in addition

15 Today's meeting will run no later than 6 p.m.,

16 beginning with a background presentation on the

17 Advanced Notice of Proposed Rulemaking and then

18 proceeding to the public presentations. We will have

19 one ten-minute break at around 3:00. There are public

20 restrooms in the hall outside the meeting room here. We

21 ask that each of the presentations be limited to around

22 ten minutes so that we'll have ample time for all to

23 provide comments. Today's spoken comments will go into

24 the publicly available docket and be available for

25 public viewing at regulations.gov.
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1 Again, thank you for coming today. Let me

2 now turn things over to Tom Simons, who will give you

3 some background on the Advanced Notice of Proposed

4 Rulemaking.

5 MR. SIMONS: Thanks, Dan. Welcome all. I'm

6 Tom Simons. I'm going to give you a quick rundown of

7 what the intent of this meeting is and a little

8 background of the PCB program. I think one of the key

9 things that I want to point out here is this word

10 Proposed Rulemaking. Nothing in this rule has been

11 decided for what we proposed. This is to get data,

12 information, and comments from the public on where the

13 agency should go. We're going to talk a little bit

14 about what PCBs are, what they were used for, health

15 effects, what is the authority under the Toxic

16 Substances Control Act for this rulemaking, what the

17 standard is for removing a use authorization -- that

18 means not allowing documented use of PCBs -- let's just

19 say transformers for simplicity sake here -- what the

20 objectives of the rulemaking are, what kind of

21 information we are looking for and what the timetable

22 is.

23 PCBs are a group of 209 different compounds

24 called congeners. About 50 of these were used

25 commercially in dielectric fluids and in carbonless
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1 copy paper. And we'll see a slide that shows some of

2 the uses that are currently out there. Back from 1929

3 until 1977, about 1.4, 1.5 billion pounds of PCBs were

4 produced, and before our regulations on disposal and

5 other things half of that material was released into

6 the environment. Now, PCBs have some great properties,

7 elasticity, heat resistance, low electrical

8 conductivity, so it was used in a myriad of different

9 applications. There are some, I would say those first

10 three, dielectric fluid, hydraulics, and heat transfer

11 probably were the bulk of the fluids used as a

12 dielectric in these pieces of electrical equipment. It

13 got down to the cutting oils, lubricants, rubber,

14 paints and coatings, caulks, pasteurizes, inks and

15 pigments, and you'll see the asterisk there. Since we

16 weren't informed to a great extent, back in the late

17 '70s, that these uses existed, they didn't get

18 authorized. Someone came forward and said it's in

19 carbonless copy paper. That may sound odd to you all

20 that that's in there. They didn't get authorized.

21 Quickly, health effects, acute, short-term

22 effects, irritation and burning of the eyes and face,

23 and chloracne, it's a skin irritation. And the chronic

24 and reproductive effects, developmental effects, and is

25 probably a human carcinogen and in studies it has shown
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1 cancer in some animals. The authority is under Section

2 6E of TOSCA. PCBs were the only chemical specifically

3 written into the act for the agency to regulate. It

4 generally bans the manufacturing process, distribution

5 in commerce, and use of PCBs with exceptions. And they

6 will have to find no unreasonable risk to an exception

7 for continued use. Most of these exceptions are, let's

8 use transformers again, quarterly inspections, use

9 restrictions, repair restrictions, constraint limits,

10 location restrictions, etc. As I said, specifically in

11 Section 6E, 2B, that allows the EPA to authorize, by

12 rule, continued use and distribution in commerce of

13 PCBs in an enclosed manner, provided these present no

14 unreasonable risk. And EPA, in '84, made the

15 determination that certain non-totally enclosed PCB use

16 activities would not present an unreasonable risk and

17 proposed continued use we said we would reassess those

18 authorizations. And you know the government doesn't

19 work that quickly, so it took us some time to get to

20 the point where we are now doing something. So we are

21 in fact doing something.

22 So the standards for removing a use

23 authorization -- that means something that is currently

24 allowed -- would no longer be allowed, that EPA must be

25 less than arbitrary and capricious. The burden to
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1 remove a use authorization is much less than a finding

2 of unreasonable risk burden to establish a use

3 authorization, and that was -- you'll see the citation

4 there at the bottom, the Fifth Circuit decision, back

5 in August of 2000. The objective: To assess these

6 current use authorizations to determine whether they

7 may now pose an unreasonable risk on human health and

8 the environment. And this rulemaking solicits comments

9 from you, other folks in the public on several -- it's

10 actually quite a few, if you look at the Federal

11 Register, you'll see subquestions on various topics.

12 These were some of them: Population,

13 characteristics for equipment, number of transformers

14 out there, capacitors, small capacitors, heat transfer

15 systems, how is this equipment being managed, is the

16 stuff that is being stored for reuse out in the back,

17 40 uncovered and leaking. What is the rate of

18 equipment failure, insurance cost. Some of these units

19 now are 40, 50 years old. What would it cost to remove

20 and replace a transformer that you have. I'm just

21 using transformer for example for purposes of this

22 conversation. What is the impact of a spill, a fire

23 for that matter. Weather events, you know, lightening

24 strikes, guys out having fun with their 22s, shooting

25 transformers. Disposal of metal recycling capacitors
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1 and costs. What is the cost of - - they want to know

2 the impacts of substitutes for PCBs, and also

3 considering some authorizations for some non-liquid

4 PCBs.

5 As Dan pointed out, the comment period

6 comments submitted at that website, use that docket

7 number, and our job will be to start looking through

8 these and formulating what would be a proposed rule.

9 I'm going to guess, sometime in 2011. Don't hold me to

10 that.

11 MR. SCHREIBER: Thanks, now we will have the

12 period for public comment. Our first speaker is Jim

13 Roewer, Executive Director of USWAG.

14 MR. ROEWER: My name is Jim Roewer. I'm the

15 Executive Director of the Utilities Solid Waste

16 Activities Group, which is a trade association of about

17 100 electrical utilities, electric generating expenses

18 and trade associations involved in the generation,

19 transmission and distribution of electricity. Over the

20 past 30 years, we have engaged with the EPA as the

21 agency has developed and implemented and enforced PCB

22 regulations as they relate to electric and gas and

23 operations, and I appreciate the opportunity to speak

24 with you today.

25 First, I want to reiterate our request which
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1 we formally submitted last month, while we are still

2 determining the most efficient strategy for gathering

3 information requested by EPA. It is very clear that a

4 thoughtful and thorough response to the hundreds of

5 questions that the agency poses in this Advanced Notice

6 will require significantly more than the 90 days they

7 have allotted.

8 Second, while we appreciate the need to

9 revisit the TOSCA PCB use authorizations or regulations

10 30 years after their promulgation, the phaseout

11 contemplated in the proposed rule is neither practical

12 nor necessary. Let me first explain why we believe a

13 mandatory phaseout is not necessary. In short, we have

14 already made great progress in an aggressive and

15 voluntary phaseout effort marked by the removal of a

16 large percentage of all PCB containing equipment.

17 Speeding up the time line for identifying and removing

18 the remaining, very hard to find equipment, will come

19 at a huge cost and will hamper our cost-effective power

20 to the public. Given the progress that we have made

21 through voluntary programs, coupled with the constant

22 dwindling of the PCB equipment inventory through

23 natural attrition, the economic havoc that would result

24 from a mandatory phaseout is simply not justified by

25 any pressing need. We are already making determined
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1 efforts to reach EPA's ultimate goal of a phaseout of

2 this equipment through a reasonable and practical

3 approach that will not compromise our commitments to

4 our customers and the public at large.

5 I want to remind EPA of what we've already

6 accomplished. For years, we have been a leader in this

7 effort promoting a voluntary accelerated phaseout of

8 PCB containing equipment, far beyond what is required

9 by the regulations. The result of this effort has been

10 significant, and inventories of PCB containing

11 equipment are rapidly decreasing. I have attached to

12 my testimony a member company reduction efforts update,

13 which we had provided EPA earlier as Strategy, which

14 illustrates the efforts that utilities across the

15 country have made to voluntarily reduce their PCB

16 inventories. Some USWAG member companies have voluntary

17 removed certain large categories of known PCB

18 transformers from their systems far ahead of their

19 equipment's normal retirement age. Many USWAG members

20 have made sure they implemented procedures to ensure

21 that most PCB contaminated distribution transformers,

22 when they come in from the field, are either disposed

23 of or retro filled with non PCB oil before being

24 returned to service. The bottom line is that this

25 successful voluntary effort is continuing to remove
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1 PCBs from service. Given the success of these ongoing

2 programs, the requirement that the utilities eliminate

3 all PCB containing equipment from their inventories by

4 an arbitrary deadline might result in, at best,

5 incremental gains in the rate at which this equipment

6 is already being removed from service through the

7 voluntary phaseout, coupled with natural attrition. And

8 while the utilities will need to employ to comply with

9 what is ultimately an unachievable objective would come

10 at a steep cost, not only to the utility industry, but

11 to the public we serve. I also want to emphasize that,

12 while our voluntary phaseout efforts are impressive,

13 the fact that companies are engaging in some voluntary

14 programs with remarkable success cannot be interpreted

15 to mean that across the board identification removal

16 from service and replacement of all PCB containing

17 equipment by a hard-and-fast deadline will be

18 achievable. That simply is not the case. That leads

19 to my second and perhaps most important point, the type

20 of phaseout being contemplated is not only unnecessary,

21 it's really not practically achievable. To ensure

22 compliance with a mandatory phaseout, utilities would

23 have to visually inspect or test, visually, all the

24 equipment within their service territories. This will

25 require service interruptions and will jeopardize both
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1 the integrity of fully intact functional equipment, as

2 well as the mandated phaseout will require the

3 expenditure of billions of dollars, which will lead to

4 costs for all electric consumers and will also have a

5 ripple effect on the supply and demand of replacement

6 electrical equipment and potentially lead to service

7 disruptions or shortages. In understanding of these

8 points, it is critical to recognize the significant

9 physical and operational differences among utility

10 generator transmitters and distribution companies. The

11 electric equipment inventory is spread very widely from

12 one utility to another in terms of size, depth,

13 function, and configuration. Some of our association

14 member companies are very small in scale and have very

15 limited resources. For example, 50 of National Rule

16 Electrical Cooperative Association, one of the USWAG

17 members cooperatives, have fewer than 25 employees.

18 Other companies face resource challenges posed by

19 systems that span hundreds of thousands of square

20 miles. In addition, utilities are contained by the and

21 the common need to provide a reliable and affordable

22 service to the rate paying public. What is achievable

23 for one company cannot be measured by the

24 accomplishments of a differently situated company. In

25 addition to the unique limitations and challenges each
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1 utility faces, all utilities are now faced with a

2 common hurdle, which now complicates any phaseout

3 effort. As the remaining inventory of PCB containing

4 equipment continues to shrink, still unknown PCB

5 containing pieces of equipment become harder to find.

6 Literally, they are a needle in a haystack. What's

7 more is the difficulty of identifying the ever

8 shrinking universe of PCB containing equipment

9 increases dramatically, so does the per unit cost of

10 doing so. In considering the impracticability of a

11 phaseout requirement, it is important to remember that

12 when the agency originally promulgated the use

13 authorizations for PCB, that Tom referred to earlier,

14 for electrical equipment, it did so only after it made

15 a determination that the risk to human health and the

16 environment. Over the past three decades, this risk

17 must have decreased because the number of PCB

18 containing items in electrical equipment have

19 drastically reduced through our voluntary efforts. The

20 challenges associated with a mandatory phaseout cannot

21 be overstated. There are literally millions of pieces

22 of dielectric fluid filled electrical equipment at

23 service along millions of miles of transmission and

24 distribution networks, where there is not any certain

25 way, except for testing or physical inspection of,
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1 visually, each and every piece of equipment to ensure

2 that all of the remaining PCB containing equipment is

3 identified. To engage in such a massive undertaking

4 and testing program will come at a very steep cost that

5 will, of course, be passed on, at least in part, to

6 electric consumers.

7 Nearly 30 years ago, when EPA promulgated the

8 use authorizations, we estimated the cost associated

9 with equipment of $6.4 billion. We're going to be

10 updating those numbers, but, today, the per unit costs

11 that I referred to are unquestionably higher, and as we

12 start looking for the needle in the haystack, that $6

13 billion number is going to be significantly higher in

14 2010. When Canada proposed a phaseout of PCB

15 containing electrical equipment, we estimated the cost

16 of complying with that program down here in the United

17 States, and we had some member companies, some

18 utilities, that considered the cost implication

19 identify with certainty the type and location of PCB

20 containing equipment. A large utility estimated the

21 cost at approximately $270 million. A smaller utility

22 estimated the cost at about $10 million. These

23 estimates don't include other collateral costs, such as

24 service disruptions, increased risk of spills from the

25 analysis of otherwise perfectly intact nonleaking
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1 equipment and the premature retirement of valuable

2 equipment. For both the large and the small company,

3 the largest identification of all PCB containing

4 equipment in their systems that were created by a de

5 facto requirement to test each and every piece of

6 equipment. Other members of USWAG agree with that, that

7 that is the most difficult part of undertaking a

8 Canadian-like PCB phaseout.

9 While we plan to develop updated cost data

10 for EPA, it is certain that the cost for the electric

11 utility industry would amount to many billions of

12 dollars. There is one final point I would like to

13 address. In speaking to the Canadian proposal, the

14 agency does refer to that in its Advanced Notice,

15 suggesting that a mandated phaseout is appropriate here

16 in the US because it is being undertaken in other

17 countries. It is very important to consider the

18 difficulties the Canadians are faced attempting to

19 phaseout PCB equipment with the deadlines that were

20 established by the Environmental Canada Regulation. The

21 Canadian Electric Association stated that large scale

22 testing required in order to achieve compliance with

23 regulations would require prolonged unplanned outages

24 and would be impossible for the electric sector to

25 schedule without placing the reliability of the power
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1 system at significant risk. The Canadian utilities

2 also raised the exact point that we are making here

3 today. It is simply impractical to engage in such a

4 large scale testing program to determine the PCB

5 content of equipment in which the PCB content is

6 unknown.

7 In closing, I would like to reiterate that

8 USWAG shares EPA's goal of removing PCB containing

9 equipment from service, as shown by our continued

10 promotion of voluntary phasedown programs within our

11 membership. At the same time, we have to caution that a

12 mandatory phaseout is both unnecessary, given the

13 continuing success of these voluntary programs, and

14 wholly unwarranted in terms of cost and risk. And on

15 behalf of USWAG, I thank you for the opportunity.

16 MR. SCHREIBER: Ms. Davis.

17 MS. DAVIS: Good afternoon. My name is Mary

18 Davis and I am the Principle Environmental Specialist at

19 American Electric Poswer in Shreveport, Louisiana. And

20 boy does the weather remind me of home. Yesterday more,

21 hot and humid.

22 During the course of my 31-year career with

23 AEP, I have served as an internal PCB auditor for the

24 company and currently am the senior professional

25 responsible for PCB compliance, not just operational
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1 guidance within AEP. Since 2001, I have served as the

2 chair of the PCB committee for USWAG and still

3 currently hold that position. You heard from Jim that

4 USWAG is a trade association of power generation,

5 transmission, and distribution companies. The USWAG PCB

6 committee has interacted closely with the EPA for the

7 last 30 years regarding all the aspects of the PCB

8 regulations as they relate to electric and gas company

9 operations.

10 Over the past three decades, I have come to

11 know many of the dedicated EPA professionals who work

12 diligently to administer the day-to-day aspects of the

13 PCB Committee, my testimony is on behalf of my company,

14 AEP. Given my limited time and the broad scope and

15 magnitude of the Advanced

16 Notice of Proposed Rulemaking, I'm going to

17 limit my testimony to three critical issues: The need

18 to extend the comment period to provide adequate time

19 for a thoughtful response from the regulated guarantee;

20 the problematic assumption that utilities already or

21 can easily identify all PCB regulated equipment within

22 their systems; and the misconception that equipment is

23 more likely to release PCBs as it ages. AEP would like

24 to respectfully state that we need more time. The

25 ANPRM raises an overwhelming number of complex issues
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1 and asks over 200 questions on a wide array of PCB

2 inventory management and related matters. AEP staff

3 must work this voluminous data response into our

4 already full-time responsibilities, and it is simply

5 not practical to effectively and thoroughly respond to

6 such an intention and varied array of issues in such a

7 short period of rulemaking initiative, it is critical

8 that EPA give everyone potentially affected enough time

9 to gather and provide the agency with accurate

10 information. Too much is at stake in this rulemaking,

11 so an extension of the comment period is currently

12 warranted and needed.

13 Secondly, identification of all PCB regulated

14 equipment is very, very problematic for electric

15 utilities. The notice assumes that measures like

16 mandatory phaseout or marking of all known or assumed

17 PCB articles should not be that burdensome, because

18 companies should be able to readily identify all of the

19 PCB regulated equipment in their systems, however, it

20 will be burdensome, and that is not true. The existing

21 PCB regulations have never required owners to identify

22 PCB regulated equipment, precisely because the agency

23 recognized it would be too difficult and cost too much.

24 EPA now believes that owners should have already

25 implemented a plan to locate any regulated equipment
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1 through the use of bar positioning systems or by other

2 means. Over the last 30 years, since the PCB

3 regulations were implemented, AEP has made significant

4 strides in reducing the number of PCB related articles

5 in our system, including identifying regulated articles

6 and removing the most accessible equipment. However,

7 AEP cannot state at this time where every piece of PCB

8 regulated equipment in our system is located.

9 AEP does take PCB equipment phaseout

10 seriously. AEP has been working on a voluntary and

11 proactive basis to identify PCB regulated equipment and

12 remove it from service. In fact, we received multiple

13 awards this year and another in 2008 from EPA National

14 Partnership For Environment Priorities for voluntarily

15 removing a combined total of over 96,000 pounds of PCBs

16 from service at two AEP coal fired power plants, the

17 Amens plant in St. Albans, West Virginia, and

18 Transatlantic River Plant in Cleveland, Virginia,

19 through the early retirement of PCB transformer

20 rectifier sets proud of these efforts, we believe that

21 it is important for EPA to understand that the early

22 removal of just these 62 discreet pieces of equipment

23 costs approximately $2.6 million and took over a year

24 of planning and execution to ensure against

25 compromising our obligation to provide reliable
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1 electric service for the thousands of customers who

2 rely on these facilities for power.

3 In order to sample all pieces of electrical

4 equipment throughout AEP's 197,000 plus miles of

5 service territory to identify items in fact contain

6 regulated levels of PCB would again be burdensome,

7 expensive, and an unnecessary undertaking, which would

8 pose safety, physical, logistics and reliability

9 hurdles. AEP knows where certain regulated pieces of

10 mechanical equipment are located, such as the PCB

11 transformers we mentioned earlier and large PCB

12 capacitors that are still in service. However, this is

13 not the case for remaining assumed PCB contaminated

14 transformers, such as pole top and Padmount

15 transformers, and in service in AEP's large electrical

16 distribution system.

17 As EPA correctly reasoned, in 1979, when it

18 accomplished the PCB assumption rules for electrical

19 equipment, it simply was not practical or even readily

20 feasible to determine the PCB content in the tens of

21 millions of pieces of equipment in service across the

22 United States. Such an undertaking would have come at

23 a massive cost, estimated by USWAG at the time to be

24 over $6 billion, which was in 1982. The same

25 challenges that EPA recognized in identifying every
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1 piece of PCB regulated electrical equipment nearly

2 three decades ago remains today. But today, it will be

3 even more difficult and more expensive, as you heard

4 Jim Roewer so aptly explain. This is because the total

5 number of electrical equipment items in service has

6 grown dramatically as the AEP system has expanded,

7 while the number of PCB containing systems units has

8 dwindled due to the ban on PCB production and the

9 subsequent change out of efforts.

10 Now, the percentage of equipment that

11 contains PCBs is far less than in 1982. In our

12 opinion, that declining percentage makes it an even

13 more inefficient use of resources to search out PCB

14 regulated equipment before the end of its useful life.

15 Thirty years ago, EPA agreed that such a search would

16 not be necessary and the case for not implementing a

17 search is even stronger today. In addition to cost

18 concerns, the practical and operational challenges of

19 identification are problematic. As a practical matter,

20 determining what equipment definitely contains PCBs

21 would require AEP to almost visually examine every one

22 of the millions of pieces of items of equipment in our

23 system, and, in many cases, to sample the dielectric

24 material in the equipment. We believe that such an

25 effort would show that only a very small percentage of
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1 equipment in service today contains regulated levels of

2 PCBs. To undertake this massive effort will require

3 hundreds of in sampling, disposal, replacement costs,

4 and outages that would directly impair our obligations

5 to provide continued reliable power to AEP's over 5.2

6 million customers.

7 AEP also has safety concerns about sampling

8 energized equipment. We would like to point out that

9 the act of sampling can destroy some equipment, as is

10 the case with bushings and light valves, or compromise

11 its integrity, as would be the case with in service

12 energized distribution transformers. To sample fluid in

13 energized distribution pole top transformers, we would

14 have to use a power-activated AMPACT cartridge gun to

15 puncture an otherwise intact perfectly functioning

16 piece of equipment to obtain a sample of the dielectric

17 fluid. Any time you puncture a piece of equipment, you

18 greatly increase the odds of premature failure and also

19 increase the odds for releases that would not have

20 otherwise occurred. In Padmount transformers, all of

21 them must be de- energized in order to be sampled. Even

22 assuming that it is possible way, every piece of PCB

23 regulated equipment, the risk to our employees and

24 service interruptions would far outweigh any potential

25 environmental health benefit. To the point that the
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1 universe of PCB regulated equipment is declining in

2 2008, the AEP operating subsidiaries disposed or

3 recycled 31,149 distribution transformers and less than

4 half of 1% contained greater than or equal to 500 parts

5 per million PCBs. Also, in 2008, we disposed of 3,356

6 large capacitors, and only .2% were contained, again,

7 greater than or equal to 500 parts per million PCBs.

8 AEP believes that the risk of releases from PCB

9 regulated equipment is far, far less today than it was

10 in 1982, and we believe that it makes no sense to incur

11 enormous cost to track down the needle in the haystack,

12 the small percentage of remaining PCB regulated

13 equipment, when the overall risk of PCB release from

14 this equipment is much less than the risks were in

15 1982. Even then, EPA determined there was no

16 unreasonable risk to universe of PCB regulated

17 equipment. If it did not make economic or practical

18 sense to require utilities to identify a much larger

19 universe in 1982, then why now?

20 And, lastly, there is not a correlation

21 between the failure of electrical equipment due to age

22 and a release of PCBs. Based on AEP data, there is no

23 basis to say that equipment is more likely to cause a

24 spill, let alone a release of PCBs simply because it is

25 ageing. Oftentimes, equipment failure does not mean
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1 you had a spill, and it's simply replaced with a no PCB

2 piece of equipment. In addition to AEP's voluntary and

3 proactive efforts, this natural attrition is

4 contributing to the ultimate phaseout of PCB related

5 regulated equipment. The integrity of vintage equipment

6 would be compromised by any sampling done to satisfy

7 the suggested identification requirements. Those

8 measures would greatly increase the risk of spills

9 resulting from the destructive sampling required to

10 take analysis of the sampling fluid from an piece of

11 equipment.

12 On behalf of American Electric Power, I thank

13 you again for the opportunity to participate in this

14 process and to present some of our views on this

15 important rulemaking effort.

16 MR. SCHREIBER: Thank you. Our next speaker

17 is Aurelia Greene, on behalf of the Deputy Bronx

18 Borough President.

19 MS. GREENE: Good afternoon, distinguished

20 members of this panel. I'm here this afternoon to

21 provide testimony from Borough President, Ruben Diaz,

22 Jr. of the Bronx. We want to thank you for the

23 opportunity to address you today on this very important

24 issue, the protection of our most precious resource,

25 our children, from the dangers of PCB contamination in
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1 our schools. As I'm sure you're aware, last June, my

2 partner in government, Borough President, Ruben Diaz,

3 Jr. wrote a letter to Administrator Jackson describing

4 the discovery of widespread PCB contamination in New

5 York City school buildings. In his get the EPA to

6 formulate a comprehensive program to identify and

7 remove the PCBs in our schools as required by the Toxic

8 Substance Control Act. Since last June, the agency has

9 taken certain steps to begin to address this problem,

10 including, among other things, entering into a

11 settlement agreement with the City of New York, which

12 will require the city to study and formulate a citywide

13 PCB management plan for city public schools. These

14 actions taken by the agency indicated to me that it was

15 willing to acknowledge the seriousness of the problem,

16 make an effort to determine the scope of the problem

17 and attempt to craft a reasonable solution. However,

18 the Advanced Notice of Proposed Rulemaking published by

19 the EPA in the Federal Register on April 7th, 2010

20 totally calls into question whether the EPA for

21 considerations of and convenience and money just wants

22 to sweep this problem under the regulatory rug.

23 First, the borough president and I are

24 outraged that this agency has solicited the 50 parts

25 per million standard for PCBs in windows and door
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1 caulking, without any apparent scientific

2 justification, and, in your own words, for the purpose

3 of relieving the "undue financial burdens" of

4 remediating PCBs in public buildings and school

5 buildings in light of the fact that the agency will be

6 conducting research on the issue of PCB contaminated

7 caulk in schools and is working with the New York City

8 public school system on formulating a model management

9 plan. The implication of this request for comment is

10 obvious for all to see that this agency is seeking a

11 justification to increase the PPM limit for PCBs in

12 order to relieve school systems to the financial burden

13 of removing PCB contamination in the schools. Without

14 the benefit of any of their own research, the EPA

15 appears to have predetermined that avoiding the cost of

16 PCB removal is worth more than the health of our

17 children and school employees.

18 Second, while we applaud the agency for

19 concentrations of PCBs in schools and methods of

20 mitigation, these studies lack a crucial element, the

21 quantification of PCB levels in the tissues of and

22 blood of school children and employees that should form

23 the basis for any change in the regulation of PCBs in

24 schools, without creating a nationwide database on the

25 levels of PCBs present in the bodies of school children
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1 and employees in PCB contaminated school facilities.

2 There is no rational basis for amending the PCB

3 regulations. In buildings with PCB contaminated caulk,

4 determining transient air levels of PCBs and then

5 projecting human exposure levels is a complicated and

6 grossly inaccurate art at best and can never quantify

7 the actual levels of PCB contamination a child may

8 suffer from, regardless of whether the contamination

9 originated from school facilities and/or off-sight

10 sources. There is no reason the EPA should not be

11 working with the CDC and other appropriate agencies to

12 create such a database and establish contamination just

13 as children are tested for led contamination.

14 Finally, the EPA published the Advanced

15 Notice with no outreach to any stakeholders and other

16 concerned parties and has not scheduled a sufficient

17 number of hearings on the topic. The issue of PCB

18 contamination of schools is one of the growing concerns

19 of parents all over this country, yet the only notice

20 given on these important hearings was printed in a

21 publication no one reads.

22 Moreover, the scheduling of only four public

23 meetings to deal with the numerous issues addressed in

24 the Advanced Notice all within 24 days is totally

25 inadequate for stakeholders to adequately prepare
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1 thoughtful comments for the EPA. The lack of a public

2 hearing in California or Texas is incomprehensible.

3 Public hearings should be held in at least

4 the ten cities with the largest school populations.

5 The overriding sense created by the short notice, the

6 inadequate notice of public hearings, and the short

7 time frame for hearings shows that has to say on PCB

8 contamination or public schools or any other issue

9 identified in the Advanced Notice. We respectfully,

10 yet strongly, urge the EPA to take the following

11 actions: Number one, amend the Advanced Notice to

12 remove the request for comment on amending the 50 PPM

13 standards for PCB contaminated substances and all

14 questions related there to. Two, amend the public

15 meeting schedule to provide for a series of public

16 meetings on each issue identified in the Advanced

17 Notice.

18 With respect to PCB contamination of public

19 schools, we recommend the agency to schedule public

20 hearings in at least the 10 cities with the highest

21 school populations over a period of 12 months and (3)

22 work with other federal agencies in creating a national

23 database on PCB levels in school children and employees

24 in buildings known to be contaminated with PCBs to

25 better understand the scope of the problem while
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1 working to institutionalize PCB testing for children in

2 public schools.

3 We understand that construction-related PCB

4 contamination is a nationwide problem which extends

5 beyond school buildings and will require significant

6 resources to address for decades to come.

7 However, an attempt to regulate the problem

8 away is a terrible solution which will continue to

9 expose our children to a serious threat of unknown

10 proportions.

11 This method of dealing with the problem is

12 something we would have expected from the previous

13 federal administration. The Obama Administration is

14 better than this. We are better than this.

15 Thank you for your time and for your

16 consideration.

17 [Applause.]

18 MR. SCHREIBER: Thank you. Our next speaker

19 is Jonathan Davis, representing Linda Rosenthal of the

20 New York State Assembly.

21 MR. DAVIS: Thank you. My name is Jonathan

22 Davis, representing New York State Assembly Member

23 Linda Rosenthal, who represents the Upper West Side and

24 portions of Hells Kitchen Clinton Neighborhoods of

25 Manhattan and is unfortunately in Albany right now.
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1 According to the EPA's Advanced Notice of

2 Proposed Rulemaking on the agency's potential

3 reassessment of its current authorizations for PCB use,

4 the agency is planning to change the level of 50 parts

5 per million in caulk which "may be widespread and may

6 be an undue burden for schools if the exclusion

7 continues at 50 parts per million."

8 Assembly Member Rosenthal stands in

9 opposition to raising the current regulatory level of

10 PCBs in caulk and is appalled that such an undertaking

11 is being attempted by the EPA which widely states that

12 the 50 parts per million standard which has been in use

13 since 1979 is based almost entirely on economic

14 considerations.

15 The dangers of PCBs are well documented and

16 people gain exposure to them through ingestion of PCB17 laden food and also through inhalation and physical

18 touching of PCBs that fall off from caulk present in

19 school and other buildings constructed using the

20 chemical before its ban.

21 PCBs have been observed to cause

22 cardiovascular, endocrine, immune, and cognitive

23 damage, in addition to other complications. In

24 children, whose developing systems are exposed to PCBs

25 in schools throughout the school year, exposure has
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1 been additionally linked to attention deficit

2 hyperactivity disorder, increased aggression, and many

3 other symptoms that constitute a serious impediment to

4 cognitive development and learning.

5 Because children are of smaller size than

6 adults and have bodies that are still developing, their

7 absorption rate is greater than that of adults and this

8 can cause additional damage in the future.

9 While it is economic concerns that seem to be

10 the driving force behind this proposed regulation

11 change, we must not put aside the steadily-growing and

12 already-conclusive body of evidence that PCB exposure

13 at 50 parts per million levels has a measurably harmful

14 consequence.

15 At a time when the EPA is broadly reassessing

16 PCB standards, using updates of our scientific

17 understanding of the toxins to strengthen existing

18 standards and eliminate some authorized PCB uses all

19 together, this specific proposal stands shockingly

20 apart in its intent.

21 Assembly Member Linda Rosenthal's involvement

22 in the still emerging crisis of PCB contamination in

23 New York City schools began in 2008 with news that

24 caulk material containing PCBs had been detected at

25 P.S. 199, an elementary school in the Assembly Member's
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1 district that was constructed in 1968, more than a

2 decade before the EPA banned the substance through the

3 Toxic Substances Control Act.

4 Of the eight different locations tested for

5 PCBs by the Daily News as part of an investigatory

6 story, P.S. 199 had the highest recorded concentration

7 levels. Parents and members of the general public

8 subsequently learned that the Department of Education

9 had performed testing immediately after an extensive

10 window replacement project had taken place which did

11 not follow protocols promulgated by the New York State

12 Education Department and which used inadequate safety

13 procedures in the clean-up and waste removal and

14 disposal process.

15 This led to a hastily-scheduled emergency

16 clean-up in response to an outcry by the parents,

17 elected officials, and the public. This experience and

18 the growing realization that this PCB issue was truly a

19 citywide phenomenon led Assembly Member Linda Rosenthal

20 to introduce legislation in April 2009 requiring the

21 testing of PCBs in all schools constructed or

22 rehabilitated within the 1950 to 1980 time period in

23 which PCBs were used by January 1st, 2012, and to have

24 50 percent of all testing completed by July 1st, 2011.

25 Assembly Bill A-7556(a) has now attracted
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1 over 20 additional sponsors from all five boroughs and

2 remains the best available option for systematically

3 assessing the risks that New York City's children as

4 well as faculty and staff have and continue to be

5 exposed to for at least 10 months out of the year.

6 Following the January 2010 announcement that

7 the Department of Education and the EPA had agreed to a

8 five-school pilot program, Assembly Member Rosenthal

9 lauded this accomplishment as a positive first step.

10 Since then, the Assembly Member has become increasingly

11 concerned about both the methodology and the standards

12 that will be employed in these tests.

13 The Assembly Member is concerned whether the

14 air testing will be of the passive or active type, the

15 lack of testing of the caulking itself, and the limited

16 number of schools involved in the pilot program.

17 Surely these five schools cannot serve as the

18 last word on the status of contamination in hundreds

19 upon hundreds of school buildings, and if the EPA

20 changes the level of PCBs allowed to remain in air and

21 caulking in school buildings, then the dilution of

22 standards based on economic and not scientific concerns

23 might render this pilot a less than helpful exercise.

24 While Assembly Member Rosenthal continues to

25 advance this legislation in the New York State
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1 Assembly, she is deeply disturbed by the purpose of

2 this hearing which is to reduce our nation's

3 environmental and safety standards regarding PCB

4 contamination in caulk from 50 parts per million to an

5 undetermined and higher concentration which would

6 preemptively reduce the clean-up and mitigation costs

7 associated with this contamination.

8 It would have been better had the EPA widely

9 publicized today's hearing rather than solely relying

10 on its publication in the Federal Register. Sadly,

11 similar cost-based arguments rather than rigorous

12 science-based reasoning were often employed by the Bush

13 Administration in its abdication of environmental

14 responsibility.

15 During the Bush years, scientific analysis

16 was routinely subjugated by industry concerns, both

17 outside and within our nation's environmental

18 regulatory agency. This proposed change of allowable

19 PCB levels is, however, especially disappointing coming

20 from the EPA's current leadership, and Assembly Member

21 Rosenthal believes that the EPA should withdraw its

22 proposal to reconsider the use of 50 parts per million

23 for PCBs in caulk.

24 Whether we are assessing results for the

25 five- school pilot or taking the eventual step of
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1 examining the safety of all locations that underwent

2 construction in this three-decade range, we should

3 maintain the current standards currently in place and

4 not predetermine the results before these tests can be

5 conducted.

6 If, as many activists believe, the tests are

7 returned with negative or insufficient PCB levels to

8 warrant remediation efforts, parents, teachers, and

9 community members will openly speculate as to whether

10 or not they would have been returned positive under the

11 previous and more stringent criteria.

12 For the sake of students, parents, teachers,

13 staff and the clearly sincere effort of the EPA to come

14 to a better understanding of the effects of PCBs on our

15 nation, Assembly Member Rosenthal urges the EPA to

16 resume the path of proper environmental stewardship and

17 ensure the future safety and health of those within our

18 public school ecosystem.

19 Thank you.

20 [Applause.]

21 MR. SCHREIBER: Thank you. Our next speaker is

22 Valerie Watnick.

23 MS. WATNICK: Good afternoon. Thank you for

24 that introduction.

25 My name is Valerie Watnick. I wear many hats
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1 today. I am a parent and I am also the former PTA co2 president at P.S. 199 in Manhattan, and I was the PTA

3 co-president at the time that an extensive window

4 renovation involving PCB-laden caulk was completed by

5 the New York City School Construction Authority.

6 P.S. 199 in Manhattan was a school that was

7 greatly affected by PCB releases when windows

8 containing greater than 50 parts per million, window

9 caulking, windows with window caulking containing

10 greater than 50 parts per million were removed and

11 replaced.

12 I am also, in addition to being the former

13 co- president of the PTA at P.S. 199, I am also a

14 professor at Baruch College. I teach Environmental Law

15 and Business Law and I am the author of a forthcoming

16 article this spring at the University of California at

17 Davis Law School in the Environmental Law Journal there

18 on PCBs in Schools. I have read and studied this issue

19 extensively nationwide. I believe it to be the first

20 article in a Law Review article and the first article

21 in Law Review about PCB contamination and the

22 regulation of such in schools.

23 I'm here today in my capacity really as a

24 parent and an advocate for children and as an academic.

25 In late 1970s, the EPA put the 50 parts per million
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1 maximum concentration in caulk that was allowed in

2 place to safeguard human health.

3 Indeed, the EPA stated on May 31st, 1979, in

4 its final ruling on PCBs in caulk that lowering the PCB

5 limit from 500 parts per million to 50 parts per

6 million will result, and I quote, "in substantially

7 increased health and environmental protection."

8 There is no new scientific information that I

9 am aware of and as I said, I have studied this issue

10 extensively, to suggest that we should be less

11 protective of children's health in schools today and

12 that should change our mind about lowering that

13 standard.

14 Indeed, in October 2009, EPA officially

15 recognized and put out -- recognized the dangers of

16 these substances and put out a public guidance called

17 Public Health Levels for PCBs in Schools with Regard to

18 PCB Concentrations in Air that would be acceptable.

19 They recognized how dangerous these

20 contaminants can be in school air which house children

21 on a daily basis and for extended periods of time.

22 Currently, the latest air testing at P.S. 199

23 shows that for the three-to-six-year-old population, of

24 which we have many, many children, the levels of PCBs

25 in air are still currently above EPA's public health
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1 levels that they set themselves in October 2009 and

2 this is after windows with caulking containing greater

3 than 50 parts per million were removed in that school

4 building and after an extensive effort by the New York

5 City School Construction Authority to clean up the

6 school. An extensive effort was made and yet the air

7 levels, the latest air testing results still show that

8 the air is contaminated at a level that the EPA deems

9 to be too high for the three-to-six-year-old population

10 and borderline high probably, I think the EPA would

11 agree, for children that are in the six-to-10-year-old

12 age group.

13 The New York City Pilot Study that Linda

14 Rosenthal's office just referred to is a study that

15 will look at one school in each county. It is, as was

16 previously mentioned, it is inadequate to really

17 consider what the level is and what the protections

18 need to be in place for all of the schools in New York

19 City.

20 This is a terrible, terrible effort by the

21 EPA to lower the standard that is currently in place.

22 It is an effort to say that if we cannot meet the

23 existing standard because it is difficult financially,

24 let's just lower it.

25 I respectfully ask that the EPA remove this
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1 provision in the Advanced Notice of Public Rulemaking

2 to adjust the standard for caulk downward, and I thank

3 you for the opportunity to speak.

4 I also thank you Ann Casey for ceding her

5 time to me as I have to go back and teach a class.

6 Thank you very much.

7 [Applause.]

8 MR. Schreiber: Thank you. Our next speaker

9 is Miranda Massey, New York Lawyers for the Public

10 Interest.

11 MS. MASSEY: Hello. My remarks this

12 afternoon will be brief.

13 My name's Miranda Massey, and I'm an attorney

14 at New York Lawyers for the Public Interest, in our

15 Environmental Justice Section. We're a civil rights

16 nonprofit law firm and, among other things, litigates

17 and organizes around questions of environmental harms

18 throughout the five boroughs of New York City.

19 We became involved in this matter of PCBs in

20 caulk about two years ago and the reason I'll be brief

21 is that we've submitted a letter to Administrator

22 Jackson requesting in the strongest terms that the PCBs

23 in caulk provisions from this Advanced Notice be

24 withdrawn for reasons I'll get into a little bit this

25 afternoon, got into more in the letter, and, if it's
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1 necessary to do so, will submit extensive written

2 statements before the July deadline, but we very much

3 hope that that won't be the case.

4 We think that these provisions are, to put it

5 bluntly, an intellectual embarrassment and a discredit

6 to the agency. It's clear that they were added on to

7 provisions that had been in development regarding

8 capacitors and transformers for some time, that they

9 were added on rationally and at the last minute. They

10 don't have the same degree of technical detail and they

11 are in flat contradiction with many other aspects of

12 the Advanced Notice.

13 I'll just give two examples of that. There's

14 one point at which 50 parts per million is presumed to

15 continue to be a relevant threshold standard when the

16 PCBs in question are contained within a capacitor. In

17 other words, it's an enclosed use.

18 There is absolutely no basis for EPA to be

19 considering eliminating that same 50 parts per million

20 standard in the event of an unenclosed use in a

21 classroom when it is by now very clearly established

22 that PCBs spontaneously volatilize out of caulk in the

23 classroom even when that caulk appears to be completely

24 intact.

25 If it's dangerous inside a capacitor, it's
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1 dangerous out in the open air of a classroom, and the

2 fact is that we know it is dangerous. I'll echo

3 Profess Watnick's comments about what we knew in the

4 late '70s because it turns out that the claim that this

5 was a standard adopted for purely economic reasons

6 finds no textual support. This is from the Code of

7 Federal Regulations and this is, in other words, EPA

8 talking.

9 The manufacture, processing, and distribution

10 in commerce of PCBs at concentrations of 50 parts per

11 million or greater presents an unreasonable risk of

12 injury to health. This finding is based on the well13 documented human health and environmental hazards of

14 PCB exposure.

15 We had plenty of science in 1979 to know that

16 50 parts per million, while you can't distinguish it

17 greatly from 51 parts per million or 49 in terms of

18 science, not then, not now, probably not ever, was a

19 sensible standard to adopt for the protection of human

20 health and the environment and now, decades later,

21 there's plenty more science.

22 Every month, every week some months, there's

23 a new peer-reviewed study that shows how toxic PCBs are

24 at extremely low levels of exposure. We see gender

25 abnormalities in children, disturbance of immune
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1 function, neurological deficiencies in adults, leukemia

2 in children, all of these at very low levels of

3 environmental, not dietary plus environmental, not

4 total body burden but environmental PCB exposure.

5 There's no support in science for the

6 proposal that this threshold be loosened or eliminated.

7 There simply isn't any support in science. There's

8 economic anxiety about what it will cost to enforce

9 these regulations and, frankly, that's understandable.

10 It will be expensive to enforce these regulations.

11 That's not the same thing as saying it will be

12 more expensive than not enforcing them if you make a

13 calculation that's intellectually whole and that takes

14 health costs into consideration over the course of the

15 lifetimes of the children we're talking about not

16 protecting against PCB exposure from caulk at all.

17 There are two final points I want to make

18 about why this portion of the Advanced Notice is so

19 profoundly discrediting of the EPA. The contradictions

20 textually between these provisions and the rest of the

21 Notice are something I encourage everyone in this room

22 who's interested in increasing or maintaining

23 protections against this toxin to take a very close

24 look at. It's not an easy read, as people have pointed

25 out, but the contradictions, both the logical
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1 contradictions and the contradiction in terms of the

2 degree of intellectual development of these proposals,

3 are very, very striking and they undermine confidence

4 in this move by the agency, to put it mildly.

5 The second way in which this is a disservice

6 both to the agency and to the public is in the timing.

7 As has already been noted by other people who've

8 addressed this body, EPA Region II has just reached a

9 landmark pilot study agreement with the New York City

10 Department of Education.

11 Is it adequate? No. Is it an important step

12 forward? Absolutely. At least equally importantly, in

13 October when EPA announced the new guidance's to which

14 Professor Watnick referred, it also announced the

15 launching of two scientific initiatives to gather data

16 nationwide about PCB exposure pathways from caulk.

17 To propose now when EPA has, in the view of

18 many members of the community, belatedly recognized the

19 importance of this exposure pathway and the threat that

20 it poses to children's health and has undertaken two

21 major national scientific initiatives to advance our

22 common understanding about what to do about this

23 emerging public health crisis, to announce now that we

24 should be thinking about in any way relaxing or

25 eliminating a standard that has been in place since
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1 1979 because it is health protective is, I'll say it

2 again, seriously discrediting of the agency.

3 We strongly urge reconsideration of the

4 inclusion of these provisions in the Notice. They

5 can't do any good. They can only do harm. The problem

6 that we face is not the PCB regulations, it's PCB

7 contamination in our schools.

8 Thank you.

9 [Applause.]

10 MS. DONEGAN: Thank you for letting me speak

11 today. I feel slightly out of my element. I'm just a

12 parent. I'm a mother of two children. I live in

13 Staten Island.

14 And while I do feel out of my element today,

15 I think my story is important to share with all of you,

16 if for no other reason than to grasp the impact that

17 this change could have just on one school in one

18 borough.

19 In September 2006, my youngest child started

20 3rd Grade at P.S. 53, Bay Terrace School in Staten

21 Island. That same week he turned eight. He was very

22 excited to be in 3rd Grade. It was an exciting year

23 for his school. They were celebrating their 40

24 Anniversary. Do the math. It was built in 1966.

25 It's not unlike many of the schools in Staten
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1 Island, given the population explosion post the Arizona

2 Bridge Many of the schools built around the same era

3 and I think that it would be redundant to say at this

4 point we know that the caulk was -- PCBs were added to

5 the caulk to help with that construction.

6 I've heard a lot of things about how great

7 that made the construction process for the schools, how

8 they could work into the winter, how it was pliable and

9 flexible. Sounds like a great thing. Why not use it

10 in every school building?

11 His room was on the third floor. It was a

12 southern exposure. The first week of school they went,

13 there was no AC in his room. The room was stifling

14 hot. The windows were jammed and mainly inoperable

15 because they were 40 years old.

16 The good news was that they were going to be

17 doing a window renovation in his school that year and

18 we were very lucky we'd be getting new windows. He was

19 in a CTT class. I don't know if any of you are aware

20 what that means. It's a Collaborative Team Approach to

21 Teaching. Half the children are special ed, half are

22 general ed.

23 The children that are special ed are

24 receiving services whether for a learning delay or

25 health reason and the other half, general ed. Because
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1 of this, there are two teachers in the room. One is

2 special ed, one is general ed. It's important to note

3 that both of his teachers were pregnant in their first

4 trimester of pregnancy.

5 They couldn't open the windows because they

6 were difficult to move up and down and they couldn't

7 really -- being pregnant did not want to fight with

8 them, but again the good news was the construction

9 project was on the way. We were getting new windows

10 and ACs.

11 Well, let me just give you a little

12 background on my child. He's a healthy athletic active

13 little boy. He plays every organized sport you can

14 imagine, football, baseball, basketball. Many

15 overlapping seasons, can do two hours of football

16 practice and continue on to basketball practice, all

17 the while in between running inside and outside

18 skateboarding, jumping, running, riding a bike. He

19 never stops. He's a healthy child.

20 He does, however, have asthma. He was

21 diagnosed at two. It's not unusual in the environment

22 we live in, especially this city. Most children have

23 asthma. It was usually controlled, never needed to be

24 on long-term medication, related to a winter cold or

25 virus, sometimes extreme temperatures and air, extreme
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1 cold, very mild asthma, well under control, did not

2 have any problems.

3 Between kindergarten and 2nd Grade, he went

4 to his school nurse for one nebulizer treatment related

5 to asthma. In three years, he went once. Within a

6 month of 2006, the scaffolding was up on my school and

7 the window renovation began.

8 What I also noticed and with my child is I

9 was being called repeatedly from the school nurse,

10 started out one day a week, two days a week, three days

11 a week. He was in at the nurse complaining of wheezing

12 and could not breathe and he was getting two to three

13 nebulizer treatments a day. He was picked up

14 constantly and by the time I would get there, he would

15 be so pale and sick from the inhaled steroids he

16 couldn't sit in the school if he had wanted to.

17 I don't know how many of you have asthma or

18 have children with asthma. I myself have had asthma my

19 whole life. When you can't breathe, you feel like you

20 want to jump out of your skin. Once you get your

21 medication, while you can breathe, you again feel like

22 you want to jump out of your skin. It is a steroid.

23 You are dizzy. You are shaky. Your heart is racing.

24 The amount of medication needed to help him

25 through the day there was incredible. He had never
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1 been like that in his life, never had I seen an

2 exacerbation to that degree, and it has never been like

3 that since. It was the same story day after day. He's

4 wheezing, please get him. He's on his second

5 treatment, I can't clear him. He feels sick now, he's

6 dizzy, please come and pick him up.

7 His medications were increased to four drugs

8 a day, both oral and inhaled steroids and over-the9 counter Zyrtec, in an attempt to keep him free and

10 clear, clearly breathing within the school, all the

11 while the construction was going on every night in his

12 building, new windows.

13 He always seemed better once I got him home.

14 Even on the weekends, even over school breaks, he was

15 fine. Over the Easter break in 2007, six months into

16 the job, the weather had changed, he was great. He was

17 off for two weeks and I thought we had finally crossed

18 the hurdle of his asthma season and whatever had

19 exacerbated him.

20 His first day back to school, within two

21 hours I was called by the nurse. He could not breathe.

22 Why? Why? I was at my job and couldn't understand it.

23 I spoke to the principal and I do want to say I had a

24 fantastic school, a fantastic administration, teachers,

25 nurses, custodians. We have a beautiful clean school.
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1 I had no complaints, but I wanted to know why, what was

2 going on in that school, what was going on at night in

3 that school that was creating some sort of trigger or

4 an environment that was making my child incapable of

5 breathing there.

6 It was at that time that the principal shared

7 with me that they were doing daily air studies during

8 this construction to make sure that the school was safe

9 to be open. I had no idea what kind of air studies. I

10 still don't know, but I assumed that someone was making

11 sure it was safe.

12 She also shared with me that the custodians

13 were coming in extra early to clean up after the

14 construction crews with the amount of dust that was

15 left in the school. They were cleaning and getting the

16 classrooms ready for the children and the occupants of

17 that building every day. There were over 800 children

18 in that school. I can't say how many teachers. I

19 imagine at least 60. I would say about 80 percent of

20 them were women and a good percent of them --

21 percentage of them were women of childbearing age. His

22 own two teachers were pregnant and several other

23 teachers were pregnant.

24 While I was relieved to hear that the air

25 studies were fine, I still could not figure out why my
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1 child was sick. All those nebulizer treatments, all

2 those trips to the school nurse, coughing, shaking,

3 dizzy, uncomfortable, scared, anxious, and finally me

4 having to pick him up, only to get him home and see him

5 improve.

6 The principal and the vice principal did

7 everything they could to try and help me. They cleaned

8 the room. They pulled out the rug. They shampooed the

9 rug. We knew that it was dust or some kind of trigger.

10 I knew that. I don't have to be a scientist. You're

11 all well versed in a lot of this that I know nothing

12 about, but I think if you know anything at all about

13 asthma, you know that there are environmental triggers.

14 I knew for a fact that something had changed

15 within that school. I couldn't figure out if it was

16 dust or mold, something, something was not right. The

17 school year ended. Miraculously, he became well again,

18 had a fantastic summer, running 10 hours a day, in and

19 out, every sport, swimming, biking, whatever you can

20 imagine, the kid never stops.

21 He went back to school in the Fall of '07,

22 brand-new windows in my school, air conditioning in his

23 room, fantastic, but within weeks the pattern began

24 again, back on medications, back at the nurse, two

25 nebulizer treatments, three nebulizer treatments, could
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1 not clear my child, wheezing on inhalation, wheezing on

2 expiratory, and he wasn't alone. The six other

3 asthmatic kids in the school were all behaving the

4 same, same symptoms.

5 You would arrive at the nurse's office to

6 pick up your child. It was surreal. There were four

7 and five kids with nebulizers strapped to their faces

8 sitting in the classroom. As the heat came on, the

9 conditions became worse. Again, you're the scientists.

10 You're the people in the industry. I think you know

11 how PCBs behave with radiators.

12 The radiators, the heat, they were under the

13 window that were ripped out. The school was certainly

14 treated, what I heard later, as if it contained PCBs.

15 It's important to note that the job at my school was

16 one year prior to this coming to any kind of forefront

17 in 2007 or any recommendation by anyone on how to treat

18 the jobs.

19 I knew the trigger was in the school. I

20 couldn't duplicate his symptoms anywhere, even from

21 running around in the cold for hours at football. After

22 the Christmas break, my husband and I decided we needed

23 to do something. We shared our concerns with the vice

24 principal and after consulting my child's

25 pulmonologist, we agreed -- he agreed to allow us to
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1 place an air purifier in my son's classroom, if for

2 nothing else to clean the dust out of his room to help

3 him breathe.

4 We knew the dust particulates from

5 construction were causing a problem. His job was to

6 turn it on and off every day, yet he was still

7 wheezing, still sick, and all the moms were starting to

8 ask what's up, why can't my kid breathe in this school?

9 I kind of describe my child as a canary in

10 the coal mine. I knew something was wrong. Something

11 was wrong. He had never ever reacted like that with

12 asthma to anything and we don't live in a bubble. I'd

13 be lying if I said my house was dust-free. I'd be

14 lying if I said he wasn't exposed to many, many

15 contaminants in the world we live in. Yet, it was so

16 troubling, I could not figure out why in that school

17 but I was determined to find out an answer.

18 A few -- the patterns continued and a few

19 months later, I happened to be reading an article in

20 April 2008 of my Daily News and there I saw something

21 about window construction and PCBs. What's a PCB? I

22 don't know PCB from an ABC. I don't know what it is,

23 but I knew something was wrong. I knew the condition

24 in my child's school had changed drastically with that

25 construction job, night after night ripping out
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1 windows, working, cutting, grinding. I don't know what

2 they were doing. It was not my job to watch them. I

3 just knew my child was sick as a direct cause of

4 something going on there, a major project over 10

5 months. This is not coincidence. It just isn't. It

6 couldn't be.

7 The teachers were cleaning his air filter on

8 a weekly basis and mentioned to me how dirty it was. I

9 asked them not to do that. When I read the article,

10 the air filter was home with me because I was going to

11 show it to his doctor to ask if she could write a

12 letter to help me clean his classroom.

13 That air filter, to make a long story short,

14 was tested by a lab and it contained 994 parts per

15 million of PCBs on the exterior filter. The interior

16 filter, which was more of the heap filter, had 225

17 parts per million of PCBs. That was directly taken out

18 of that classroom, cleaning that dust, filtering that

19 air that my child and 30 other children were breathing

20 all daylong in that room and two pregnant teachers and

21 that's one little classroom in one little school.

22 A question came as to where the air filter

23 had run before that. It was brought to the school

24 brand new in a box, bought at Costco for a $150. It

25 still had the tag on it in the classroom.
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1 I asked the School Construction Authority if

2 they felt that it was an inaccurate find, that they

3 should pull the air conditioning filter out of my

4 child's classroom. Certainly there would be no

5 question about what air that was filtering. That

6 filter was pulled but was never tested. This all

7 coincided with the April 2008 hearings with the City

8 Council. The SCA crawled over my school all weekend.

9 They took dozens and dozens of wipes and air samples.

10 No air testing was over 90 minutes long, not one. It

11 was done with a NIOSH method and again this is way

12 beyond my scope. You're the experts. You know what it

13 means.

14 Apparently the way the air, 90 milliliters of

15 air were forced through in 90 minutes became almost

16 impossible to detect PCBs at that rate. The wipes were

17 taken from the center of clean rooms. No vents were

18 wiped, no filters were taken, no radiators behind or

19 under where windows were pulled out were wiped. No

20 dust from anything that may have looked like it could

21 have been related to construction dust was ever tested.

22 The City agreed that the school air was PCB23 free. It was safe and free of all toxins.

24 One find was detected at 50 parts per million

25 in the 2nd Grade classroom. At the PTA meeting that
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1 night, a representative of the School Construction

2 Authority said that that could have possibly come in on

3 someone's shoe. That was not an accurate find. That

4 same find was later explained to me as a lab error or

5 so far off the scope of any find that it couldn't

6 really be accurate.

7 Again, I'm just a mom. These are the

8 experts. I don't know how you find PCBs, but I

9 certainly was able to find it myself. It was in my air

10 filter. I tested an air conditioner filter for them

11 because they would not. It had over 400 parts per

12 million of PCBs in it.

13 At one point I took a key and took a chunk

14 out of the interior caulking on the front door. It had

15 79,100 parts per million of PCBs. Every single thing I

16 was able to take from that school had PCBs in it. The

17 City was not able to find any. They did, however, have

18 to do soil studies under some direction of the EPA at

19 that time because they were somewhat involved.

20 Two to six inches down, there was a detection

21 of PCB and it was over the allowed amount. The topsoil

22 was never tested. I understand that EPA asked them to

23 test it but that was never done. I guess I should be

24 happy that a total soil remediation was done in my

25 school but it still doesn't answer what are we going to
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1 do about construction in the schools.

2 While I sit here and listen to words such as

3 budgets and burdens and billions and millions and self4 regulation and safety, I wonder where all those words

5 were in my classroom. This was a full year before any

6 recommendation by anyone to make sure what you're

7 taking out of that room was safe. There was nobody

8 watching anything. Every night it was a construction

9 zone with tons and tons of caulking being cut out of

10 the walls and the ceilings and wherever else again I do

11 not know, and the dust had little to no control in that

12 project.

13 The air studies, I came to find, certainly

14 did not have any PCB results because they weren't

15 testing for it and they still are not today. They

16 wouldn't test the caulking when they came in to check

17 the school because they didn't have to. They still

18 haven't in that particular school.

19 I have to say that there would be no reason

20 to think that the findings at P.S. 53 would have been

21 any different had it gotten the attention P.S. 199 got.

22 Had we had the air studies and attention, we might have

23 been cleaned up, as well. We are almost four years out

24 from that construction project and no one has ever gone

25 in and cleaned that school or tested it to the degree
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1 that I think it should have.

2 It's beyond my wildest comprehension as a

3 mother that someone could come right into your

4 classroom every single night and pull out something as

5 dangerous as a PCB and contaminate with dust throughout

6 the books, the desks, the toys, the rugs. There was

7 nothing covering anything. There was no one watching.

8 There was no one cleaning.

9 The whole process has been quite sobering for

10 me. I am not in the political arena. I am not --

11 again, I'll say it, I'm a fish out of water here today,

12 but it's been surreal for me to think that as much as I

13 try to protect my child and the environment we live in,

14 and I'm not naI know what exists everywhere, I can only

15 protect my child so much. When I send him to school,

16 no one is protecting him. Nobody was looking out. No

17 one has cleaned the school. No one has tested the

18 school.

19 So I'm asking that the PCB and the caulk

20 issue not fall on the back of all the other talk of

21 sources of PCBs. Somebody needs to regulate it and

22 somebody needs to assure me and every other parent that

23 this mistake will not be repeated. There's no one

24 protecting the kids in the schools and I just hope that

25 my story highlights what it really means to do
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1 construction and pull this out of a school every night

2 of the week.

3 Thank you.

4 [Applause.]

5 MR. SCHREIBER: All right. Ann, would you

6 like to speak now?

7 Okay. Well, really, it would be more

8 convenient for me if you'd speak now. I don't see

9 anyone else stepping forward.

10 MS. CASEY: Good afternoon, everyone. My

11 name's Ann Casey, and I have to say, because I promised

12 with great angst before I came, that I would put this

13 up and say it, that the opinions that I'm expressing

14 today are my own. They are not of my current employer,

15 any agency or past employer, any organization, or any

16 peer review group I have been involved with.

17 Just a little background on me for those of

18 you who don't know me. I'm a graduate of the College

19 of St. Rose in Albany. I have a B.A. in Sociology and

20 a B.S. in Biology. For the past 22 years, I've done

21 nothing but PCB work, whether it be research,

22 development, method extractions, analysis, and

23 monitoring PCBs.

24 I've co-authored eight peer-reviewed

25 publications. I've given several oral presentations on
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1 PCBs, effects of PCBs, detection of PCBs. I have

2 developed several extraction and analysis techniques

3 for PCBs into the ultra-low detections of PPT which 22

4 years ago I didn't need but today we are finding that

5 we need that.

6 I'm also a parent. I have four children. I

7 have a 13-year-old, eight-year-old triplets, and that's

8 why I was late getting down here today. I missed the

9 first train because of them.

10 I would like to commend the EPA. I knew

11 today they were going to get pounded on pretty hard

12 about this whole reauthorization process, but this has

13 been a long time coming, everyone. For the folks who

14 are new at this, we have been asking for this, I would

15 say, for the past 25 years, that we come back and we

16 look at TOSCA and we look at the 50 ppm level, and it's

17 always been tabled.

18 I mean, I can tell you meetings in the '90s

19 that I sat through right here at Region II and everyone

20 saying, you know, we're not quite there yet, we're not

21 quite there yet.

22 The reassessment's long overdue. Now, do I

23 agree with the caulk add-on to this reassessment? No,

24 I was not too happy to see that.

25 The other part of the assessment is very well
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1 thought out and obviously EPA has been developing this

2 for awhile when you read through this until you get to

3 the caulk part.

4 I want everybody to know here today this is

5 going to be a long, hard, and difficult task to

6 complete. It's not going to happen overnight. It's

7 not going to happen within the next year would be my

8 guess, to be very honest with you. It's going to take

9 awhile and I know as a parent that's hard to hear. As

10 a researcher, it's hard to say.

11 History is a great teacher, if we're willing

12 to listen and hear what's being said. One of the very

13 first research projects that I worked on when I was

14 with the New York State Department of Health was the

15 Love Canal Reassessment. Ten years after everybody

16 realized that we had children and parents and people

17 living on a toxic waste dump and what were we going to

18 do about it?

19 Right around the same time, TOSCA was coming

20 through. We didn't have a lot of the laws that we have

21 today back then. That was a very hard time in our

22 history, but it also was a wake-up call and, you know,

23 I give presentations all the time. When I go to

24 classes now, I have to find a new site because I put

25 Love Canal up and the next generation doesn't know what
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1 I'm talking about. They don't know that over 900

2 families were moved off of Love Canal because the toxic

3 waste was so great and what it looked like yesterday, I

4 remember that picture, and what it looks like today.

5 It's an open field.

6 People are reoccupying Love Canal area. The

7 clean-up's still goes on. They're still treating water

8 there. They're still measuring stuff there. It still

9 goes on and we can learn a lot from that as we start

10 with our reassessment, but that was the kick-off to

11 really environmental chemistry, to laboratory response,

12 to health department, to EPA responses, and we can't

13 forget that. We have a good solid foundation. We

14 learned the hard way, unfortunately, and sometimes I

15 don't think it gets carried through, and I think that's

16 the frustration we're hearing today from parents, is

17 that nobody's watching for my child.

18 A lot of people get really upset when I put

19 this slide on. Lois Gibbs certainly became homegrown

20 activist and what people don't realize or what people

21 have forgotten was her son John became ill in June of

22 1978. In August, that's when the state of emergency

23 was put into effect. By the next fall John was dead

24 due to kidney disease. Lois doesn't have her son here

25 today to tell us what toxic waste did to her family and
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1 it wasn't just PCBs. There was lots of other stuff at

2 Love Canal. I'm not just focusing on PCBs. But it's to

3 illustrate what happens when we're not watching, when

4 we don't pay attention.

5 So reassessments of PCBs and TOSCA. We have

6 30 years plus of research. We have lots and lots of

7 research out there. It's good research. It's research

8 that shows we were right in putting the 50 ppm out

9 there. We were right in doing that because lots of

10 people wanted 500, lots of people wanted a 100. Fifty

11 was settled on and it was enforced and we've seen the

12 levels go down in our environment which is fabulous.

13 Is it to where I want it? No, it's not. I'll

14 be honest with you. It's not. Our laboratory analysis

15 and technology improvements over the past 30 years have

16 been phenomenal. What we can do today, even in the

17 past 10 years, has moved so far in advance.

18 Northeast Analytical, who I work for, we were

19 the lead lab for the Hudson River Project of GE Clean20 up, the Upper Hudson this summer. We processed 18,000

21 samples for PCBs through our laboratory in 200 days.

22 Let me say that again. 18,000 samples/200 days. They

23 weren't just air chlor analyses, run of the mill

24 analysis. A lot of them were specific analysis down to

25 9 PPT total PCBs to make sure we were protecting not
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1 only the ecology and environmental health but people's

2 health down there during this project.

3 So we have the technology. It's there. We

4 can test. We know how to do it correctly. It's

5 getting people to do it correctly is the issue that we

6 have. Understanding PCB chemistry, that's a really

7 hard one and it's hard for everybody, even for folks

8 like me who have done this for years. Trying to

9 explain it to the lay person is hard.

10 I'll keep on with my slides here. This is

11 just to give you an idea of where I'm going to focus

12 instead of -- what's the research telling us? It's

13 telling us women and children should not be exposed at

14 any level to PCBs. We know this. We've known this for

15 years now.

16 Cancer is not the only endpoint we should

17 look at with PCBs, although it's a good endpoint, it's

18 not the only endpoint in assessing the effects of PCBs

19 and especially when we start looking at kids. That is

20 not our endpoint that we should be using.

21 For a long time ingestion was the main focus

22 of research of PCBs. What we found is inhalation and

23 dermal exposure are also very viable routes and

24 especially when you start talking about kids. We're

25 not talking about the workmen who took inherent risk
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1 taking a job of working on transformers in an

2 electrical company who knew the risk of PCBs.

3 We're talking about kids sitting in a

4 classroom where they're supposed to be trying to learn

5 and being exposed unbeknownst to them, unbeknownst to

6 their parents and even to the teachers, faculty and

7 staff of the schools. That's more the issue.

8 Like I said, we've really increased our

9 detection of PCBs, how we do it. At one time when the

10 50 ppm level was put in place 30 years ago, we were

11 sure as scientists, and I can probably prance out here

12 a hundred scientists who would say the same thing, yes,

13 we felt confident that everyone could measure 50 ppm

14 and identify the air chlor without much problem. They

15 could do that.

16 Now what we can do is we can do congener17 specific analysis, actually individual congeners that

18 make up the air chlor, and we can get it down to PPT

19 ranges. We can go much lower and we can identify the

20 air chlors much better than we used to be able to, but

21 it takes a lab that does it day in/day out and that

22 knows PCB analysis. This isn't a fly by night

23 analysis. This isn't a 50 buck a night analysis. It

24 just isn't. This is highly technical analysis, but it

25 needs to be done to get the right answer.
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1 You know, tons of lab studies have been done

2 the past 30 years. Pretty much, if you all read the

3 literature, lab studies have shown on rats that there

4 are effects at environmentally-relevant levels, not

5 dosing a rat at 50 ppm and the rat dies. No. They're

6 dosing rats down at .5 ppm or at 900 nanograms per

7 cubic meter and they're finding effects. That's where

8 the research is taking us now and something that we

9 can't forget when we're reassessing TOSCA, that the

10 research is there and we should use it to our ability.

11 This is the biggest problem. Understanding

12 the chemistry. They are a complicated class of

13 chemicals. They are manmade. So many times I hear

14 people get up and say, well, they're like lead. They're

15 nothing like lead. Lead is a naturally- occurring

16 component of our earth's crust. Have we abused lead?

17 Have we misused it? Have we disposed of it improperly?

18 Yes, we have it. Does it affect children? Most

19 definitely.

20 PCBs are manmade. They don't occur

21 naturally. You have to force them to get them. Okay.

22 They are volatile. They are soluble in water. They

23 are absorbed by animals and humans and they're great

24 mimickers. That's the problem. We can't follow all

25 the pathways.
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1 So why are we saying, oh, let's just kind of

2 slide this under the carpet here? We'll just ignore it

3 when we know this. They're all over the world. They're

4 in soil, water, food, meat, fish, milk, air, and humans

5 without a doubt.

6 I have been testing for 22 years and I have

7 seen very few human serums in bloods without PCBs in

8 them. The younger generation has them much less than,

9 say, people born between 1960 and 1978. We were the

10 greatest exposed generation and our body burdens show

11 us that.

12 PCB levels have gone down with enforcement

13 because of TOSCA. If we didn't have it in place, we

14 would be looking at levels from the 1960s and 1970s

15 still. They would have gone away. But they are still

16 in many products that are out there today and in use

17 and that's our problem.

18 We don't know all the products and where they

19 are. It's not just transformers. It's not just

20 fluorescent light fixtures. It's not just caulk. We

21 use them in everything. They have found their way into

22 every industry and if you don't believe me, if you're

23 bored and have insomnia some night, go on the Web and

24 search U.S. patents for air chlors and see how many

25 come up. It's really quite scary.
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1 We all are in contact with them every day.

2 This is not just a New York City problem. Now I know

3 the school district in New York has a huge problem, but

4 I'm here to tell you it's not just here. Pretty much

5 every major metropolitan area on the East Coast has

6 this problem. It just is a fact.

7 I mean, I have not seen -- since 2006, we

8 have tested over 1,600 caulks, 70 percent of them have

9 tested greater than 50 ppm. The very population we

10 want to keep safe are children and women of

11 childbearing years are still in contact due to the

12 products that have been in use for 30+ years.

13 Is 50 ppm a reasonable level? 30 years ago,

14 yeah, it was. I agreed with them. I don't agree today

15 that that is a reasonable level. It's too high. We

16 need to start coming down. It needs to be incremental

17 and, yes, I realize this is going to cost money.

18 I feel a fair target would be 10 ppm. I

19 would love one but I'll never get one. So I'll settle

20 with 10.

21 We also need to figure out how many products

22 are in use still 30 years later and how many are coming

23 in contact with the environment and I don't think we

24 have a really good sense of that and how long the

25 product life has. This is outside of transformers and
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1 capacitors and things like that. This is more like the

2 caulks, the mastics, the ceiling tiles, light switches,

3 paint coatings, some things like that.

4 I do not believe that products or anything

5 that has PCBs in them should be removed from TOSCA.

6 Because we've come so far, let's not set the clock back

7 because once you let one product go, everybody's going

8 to start knocking at your door, saying well, you let

9 caulk go, why can't my mastic that we use putting down

10 hundreds of thousands of linear feet of floor tiles be

11 taken out then? Where does it stop? It's not going

12 to.

13 If anything, we need more recordkeeping and I

14 know for industry this is hard. I understand you have

15 millions, if not hundreds of millions of capacitors and

16 transformers and equipment that has PCB oil in it, but

17 we need better recordkeeping and better accountability

18 and that should be in TOSCA and it should be in TOSCA,

19 not just for major industry. It should be for all our

20 public buildings, including schools.

21 Economics are important. I'm the first one to

22 tell you, yes, my job relies on the fact of how many

23 samples I can bring through the lab. It's economics.

24 But if we fail to protect our water, our food, our air,

25 and our children, then we fail to exists; and to me,
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1 that I will pay anything to protect as a parent, as a

2 scientist, and as a community stakeholder. That's

3 pretty much it.

4 (Applause)

5 MR. SCHREIBER: Okay. So I promised the

6 break at 3 o'clock. Let's go ahead with that for 10

7 minutes and reconvene at 10 after.

8 * * * * *

9 MR. WEYMOUTH: What happened to all

10 the people that were a while ago? They all snuck out,

11 huh? I'm going to put a little different twist on

12 this, ladies and gentlemen. My name is George

13 Weymouth. I've been 40 years in the bricklayers union,

14 and I worked in the outside skin of those building all

15 my life. I have two kids that are doing it now and

16 probably my grandchildren will be doing it as well.

17 Just looking out that window you can see the

18 caulking. I'd say those joints are a half inch wide,

19 no more than a quarter inch deep, and I counted the

20 floors in that building, and I'm saying there's

21 approximately 50,000 linear feet of caulking in it. I'd

22 like to go over and grab a sample. That's what I'm

23 famous for. I've taken samples in Yorktown, Boston, all

24 over Boston. I've got tons of samples, and that one

25 there look really good, and I can tell you if it come
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1 out 25, 30,000 parts per million, you've got 1,740

2 pounds of PCBs in that building either at 1260 or 1254

3 Albacar, but that's just something I've seen.

4 In the '90s, I was involved with Bob Herrick

5 in the School of Public Health in the Center to Protect

6 Workers' Rights. Now, it's the Center of Research and

7 Training, and I trained in industrial hygiene

8 principles in work to help reduce dust, silica dust in

9 the workplace; and that, of course, is a carcinogen as

10 we're all aware of. We were using control methods,

11 some kind of vacuum system hooked up to tool; and as we

12 made dust, we vacuumed that dust into a container, HEPA

13 vac, and it was disposed of properly. Not that it was

14 hazardous, it was just that it was silica, a respirable

15 silica, the molecule of which if I had in my finger and

16 dropped it right now, I'd be all finished this

17 presentation before it hit the floor, and that's a

18 respirable amount. When you see people making dust in

19 these building, what you see is naturally a volume of

20 dust. What you don't see is the smallest molecules

21 being blown two and three miles down the road.

22 At the time -- after doing that, I retired. I

23 retired in 2002. In 2003 or just before that, I get a

24 phone call from my pal over at Harvard, Bob Herrick;

25 and he says, "Let's have lunch. I've got something I
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1 want you to read." It was the Helsinki report from

2 Finland. In that report, I read about the polysulfide

3 caulking, and that really, it really struck a chord

4 because that's what I've been working with all those

5 year up until the late '70s. And I got -- I had

6 chloracne from my knees down because I can explain how

7 that stuff is mixed, and when you mix it -- it doesn't

8 come in one part. It comes in several containers,

9 several parts in one can. You dump these things in

10 color activator, and you mix it with a paddle. When

11 you're mixing it, you hold the can in between your

12 feet, and you got to move this paddle around and mix it

13 properly as it has one continuous color whether it be

14 off-white, bronze, red, whatever they want, the

15 architects want for a color. In so doing, your

16 clothing -- your -- your pant legs seems to move a bit

17 as you're mixing this, and the gases come out of the

18 can and they come up your pant legs, and that's how you

19 get chloracne. I used to go to bed scratching so bad

20 I'd be red-blood raw in the morning.

21 At this point in time, I've got a lung

22 disease. I've my first open-heart surgery when I was

23 37. Of course, I like to think it was because of my

24 second wife was quite a bit younger I was, but that's

25 beside the point.
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1 (Laughter)

2 MR. WEYMOUTH: And I've had problems

3 since. I have two children with attention-deficit

4 disorder. I have two grandchildren that have learning

5 disability problem. They have a certain -- a

6 comprehension problem when they -- when they read. And

7 I had no idea, wouldn't know what those things possibly

8 -- I knew I worked hard all my life, but I didn't know

9 possibly I may might have had things that would be

10 detrimental to my health in the workplace.

11 And as I said, as part of the dust control, I

12 felt I was really doing something for my fellow workers

13 out there when we implemented -- when we went to these

14 jobs that we had a certain dust control. We were

15 fitted for masks by professionals, and it worked, it

16 worked.

17 Just to jump ahead, I was in the meeting down

18 in New York there a few months back. I forget exactly

19 when it was. I didn't have an opportunity to speak,

20 but I was almost coming out of my chair when the

21 teachers came up to the podium and they said that

22 before their student could start class they had to wipe

23 off their desks and their chairs, and some of them had

24 to wipe off their books, and I just -- I went wild. I

25 just couldn't believe it. We don't do that in Boston.
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1 We don't work on school during the year unless it's a

2 very much an emergency repair. We hit school hard if

3 we're going to make any dust at all from the time

4 school is out during the summertime till it comes back

5 in fall especially if it has anything to do with the

6 masonry or dust, window replacement, etcetera. It's

7 just not done. It's done during those summer months,

8 so that's a big difference between, you know,

9 Massachusetts and New York.

10 I remember cutting out, you know, old

11 caulking like that building; and in order to have the

12 new silicon caulkings adhere, those -- the residue from

13 the old polysulfide would have to be removed, and you

14 do that by scarifying with an electric tool the

15 masonry, and that gives you what they call a virgin

16 surface that would enable the new silicon caulkings

17 that they use today to adhere properly.

18 There's another thing I'd like to get to as

19 far as the caulking itself. We didn't know, you know,

20 much about it other than on the can it said cause brain

21 damage. We kind of got a boot out of that because we

22 figured we all had brain damage to be in the business,

23 and it said to wash your hands before we ate.

24 Again, looking at that building over there,

25 in the corner of the windows and certain parts of the
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1 joints where the joints in the stones meets the joints

2 in the windows, it's kind of hard to get a tool in

3 there to smooth it out, so lot of times we used to do

4 that on that raw material. Many times I went down in

5 my truck and looked in the mirror and saw caulking on

6 my -- edge of my mouth, and I wasn't the only one. It

7 was -- it was a practice. We all did it.

8 After reading that Helsinki report from

9 Finland, like I say, with polysulfide, It's the same

10 identical compound that we use in this country that's

11 used in Australia, England, Germany, all throughout the

12 rest of the world. It's all the same. If you would

13 take a sample from there, it's the same -- the same as

14 that. There is it is. Right there, one little piece,

15 and this is out of your schools here in New York, and

16 it's proof positive.

17 Again, you take these guys out there with

18 that saw, cutting that masonry, not only are we making

19 the silica dust, but we're throwing PCB into the air.

20 We're making them airborne. If that school is a half

21 mile down the street, I'm affecting where we are right

22 now. Just one guy on that saw because that's how small

23 and how respirable and how far those thing will carry.

24 It's amazing, truly amazing.

25 This -- I came here prepared and yet
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1 underprepared. Just a few things that I heard, and I'd

2 like to comment about people that went before me. As I

3 said, I was retired, but I was in contact with my old

4 crew. I want to find out more about this caulking. My

5 old crew was working on an office building in Boston.

6 It was a large office building, not as large -- nearly

7 as large as the ones you have here, but it was 30

8 stories, salt-installed (ph) building. It's a Federal

9 building. I went and I saw my friends at lunchtime, and

10 I noticed that there was a few people up there in tie11 back suits. And I say "Hey, Rod, why are those people

12 up there?" He said, "Well, they're doing the abatement

13 from the caulking, but they're not doing a very good

14 job because as go by them, they miss portions that we

15 have to take care of." I said "Okay, I need a couple

16 of pieces of caulking." He said "It's all over the

17 ground under the rig." So I jumped the fence like I'm

18 so good at and went and got some samples. I got two

19 samples; one bronze that was around the windows, and

20 one white that was in the stone, and that's why -- that

21 caulking I did, you see is white, it's probably a

22 polysulfide because the problem they were having toward

23 the one was the polysulfide life where it was losing

24 its color because of the UV rays. So I'm just guessing

25 that that's a good -- good sample over here, good
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1 possibility.

2 I got those samples. I cut them in half, the

3 white and the bronze. I sent them out to be looked at,

4 to be analysis -- to be analyzed. The caulking came

5 back 26,500 parts per million on PCBs, and they came

6 back zero with asbestos. So why were these people up

7 there as asbestos people taking out this caulking that

8 didn't have any asbestos in it? Caulking burns. You'd

9 think with asbestos it wouldn't burn. Caulking burns

10 like you've never seen anything burn before, and it has

11 a thick, acrid, smoke. As soon as you breathe it, you

12 choke. That's how acrid it is. That's why firefighters

13 aren't allowed to go in buildings without some sort of

14 an apparatus. Bad stuff. And we used to burn it on a

15 daily basis after mixing so many tens of hundreds of

16 these units -- well, not -- in a day maybe 10 or 15

17 units, but at the end of the day, the paddle get --

18 would start to get hard because the caulking was set

19 up. So we'd put it in an empty can, wrap it in a --

20 the paddle, in a rag, and put a dot of tolliwall (ph)

21 on it, just enough to get it to start to burn, and it

22 would burn off, and we'd put all this black stuff --

23 you wouldn't believe it. It was a normal practice. So,

24 you know, we just infected ourselves and everyone

25 around us. So when I found out about the PCBs, I said
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1 I want to make a campaign. First of all, I apologized

2 to every kid in every school that I ever caulked, and I

3 caulk a ton of them. I apologized to the kids in New

4 York when I took the samples over by Co- op City. I

5 apologized to the people who lived in the buildings

6 over there because they're going from a contaminated

7 building with PCBs into a contaminated school with

8 PCBs. Amazing. Talk about double dose. I went home

9 at night crap on my legs and on my clothes, and my kids

10 would throw their arms around me and "Nice to see

11 you're home, Daddy." I had that stuff all over me.

12 As far the -- I'm sorry. As far the -- that

13 was my water bottle. Something -- something always

14 happens like this. I apologize. I'm always

15 apologizing. Any waterproofer worth his salt if I was

16 told to go out and get -- "Get me a sample of

17 caulking." They'd go out and get me a sample of

18 caulking. They wouldn't get me a sample that had a

19 cohesive or adhesive failure in it. Very simply, I you

20 were to take a bit of caulking with a cohesive broke in

21 the middle or an adhesive either side of the masonry

22 failure and have it analyzed, there's a 90 percent

23 chance that you'll have asbestos in it, and it caused

24 simply by the air conditioning that you hear right now.

25 The air conditioning is pushing air through the
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1 ceiling, down those cavity wall, behind the clock; and

2 if it finds a crack in that caulking, it's to go out

3 the caulking. The caulking because it's fractured it's

4 sticky, and it traps anything by from bugs to asbestos.

5 So it's very easy to find asbestos in caulking. What

6 I'm afraid of it that at some point in time in the near

7 future there's apt to be a stampede on removing

8 caulking because they're going to find asbestos in it.

9 As I say, the asbestos I remember putting into a

10 building as far as the caulking goes only went from

11 floor to floor. It was in the pipe chases. As a pipe

12 went through in one of these closets possibly, it went

13 through the next floor into the floor above, and that

14 opening space was caulked with a firesafing. It's very

15 expensive, and I certainly don't think for one second

16 that they're going to put 50,000 feet of caulking that

17 goes for like $19 a tube on the outside of a building.

18 It's not going to happen. There's no asbestos out

19 there, but it came up that way. It was brought up that

20 way because they're people who are smart enough to

21 realize how the stuff functions. You can't let

22 asbestos be abated and have it treated like PCBs. I

23 don't feel that -- that they're abated the same way.

24 As far as I know, PCBs have to be incinerated at over

25 2,000 degrees. Anything under that causes a dioxin gas.
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1 I caused dioxin gas. That's what I apologized about to

2 the kids in the schools and the people in the building.

3 It wasn't just schools. It was a lot of buildings. We

4 started out -- when I first took the 24 samples in the

5 unrecognized source of PCBs contaminants with Harvard,

6 I took all those samples. It was mostly big buildings,

7 office buildings, colleges, but it wasn't going

8 anywhere. It fell on deaf ears. So what I did I

9 looked around, and I started closing down jobs. I was

10 a whistleblower if you will. I stopped windows from

11 being thrown in a dumpster at a Catholic memorial high

12 school in Lowell. I stopped a good sized building in

13 downtown Boston. They were just letting the caulking

14 fall on the ground, sweeping it up, and throw it in the

15 dumpster. I banged them on that, got it shut down.

16 Kim Teesler (ph) and Mary Ann Mollette (ph) were very

17 quick to do that because I proved to them that there

18 was a problem.

19 The other job I that I closed down or I had a

20 lot to do with was the student housing over at MIT.

21 That job stayed actively with people in it during its

22 abatement, and I really felt bad about that. They

23 should have got those students into hotels. The reason

24 why that one was so on my list is because there was a

25 big, toddler yard that was right adjacent to the
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1 masonry. The masonry samples they're not very big. I

2 took a sample of the soil. I took a sample of the

3 caulking. The caulking was 36,000 parts per million,

4 and the sand vial as big as this one, not much. You

5 can make a nice little musical sound with it, 15 parts

6 per million 1240; 14 parts per million 1260. Talk

7 about being over the amount of PCBs in soil, this is

8 it. The first thing they did was tear out all the

9 dirt, that's all that there, backfilled everything.

10 Then they started with the building. It ended up

11 costing them $100 a foot. The reason why? It wasn't

12 just taking the product out of the joint. They

13 encapsulated the masonry because the building is slated

14 for removal. The building is slated to come down in

15 five years, so there three buildings that they spent so

16 much money on are going to be nonexistent in five

17 years. But because I blew the whistle, they wanted to

18 make everyone happy.

19 The other job -- I had gotten a little part20 time job in a glass company, and I was on the second

21 floor while they were putting -- I was a runner. I

22 went and got part for this glass company. I brought

23 some stock in, brought it up on the second floor where

24 the guys were working on this building that was

25 completely gutted on the inside, completely gutted.
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1 There was nothing in there, everything was gone, and

2 what the company with was doing they were taking a

3 window and putting a new window into an opening that

4 had been removed as a mockup, so they were going to

5 show what the new windows were going to look like. And

6 as I was there, seven men come up the stairs dressed in

7 tie-back suits, and I'm telling you booties, hat,

8 goggles, respirators, the whole nine yard; and within

9 from me to that window, they started working.

10 And because of my background of hygienist and

11 the caulking issue that I was so well-read up on, I

12 went over and I asked who was the foreman, and I asked

13 him what was going on, "Why would you be working so

14 close with these other crew, these seven men that I'm

15 working with why -- how can you do that?" He said

16 "Well, we found trace amount of asbestos."

17 That's the key word: Trace amount. That really gets

18 me. And I said "Where?" And he showed me. There's a

19 seal that hold the glass in tight. He started pulling

20 that seal to loosen up the glass, and there was a bit

21 of dust coming out, and I explained to him all that was

22 when they put that seal in they applied a soapy

23 material to the rubber, and as the new seal went in and

24 pushed it in -- just like if you're at your service

25 station and you watch them change your tire, they put a
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1 little soap on the rubber. It's slippery. But after

2 20 years, it dries; and when you pull it, hey, what

3 happens? You get a little dust. You can't tell me

4 there's asbestos in that. It's soap, but then I saw

5 him reach out the window and cut the caulking, and that

6 was it. And I said, Who's here? Who's here that I can

7 talk to? We have a fellow downstairs that's taking air

8 sample for asbestos. I went down, and I spoke to him.

9 He said, I take sample every hour on the hour. Well,

10 you know, I don't know, maybe I've been a long time out

11 of the school, but I remember having to weight those

12 little wafers that go in that machine. We send them

13 out and have them weighed for asbestos, but to tell me

14 that he was doing it on an hourly basis, I didn't think

15 that was possible.

16 I went back up stairs, and I look down and

17 the foreman said, George, look at this. I looked down,

18 and the fellow on the meter was talking to the

19 superintendent. I bailed. I had to leave. The

20 following day I'm on the -- on my way in, called the

21 foreman up to see if he needed anything. He said, Yes,

22 I need you not to come on the job. Okay. You can't --

23 you can get out of the truck. You can open up the back

24 of the truck, but you can't go on the property." Well,

25 I'm not, you know, of course, I went on. I went on,
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1 and I took a piece of caulking. I had it tested. Hot

2 for PCBs. Called Maryann Mollette. Shut it down.

3 Three months, three month -- I was -- I just couldn't

4 believe it. How can you start three months? You

5 talked about threats. I was threaten. I was threaten

6 by everybody. It's their livelihood. But you know,

7 there's a lot of people that walk around in that area

8 too, so I felt I did the right thing. I feel like I'm

9 doing the right thing now, and if there's any school

10 out there or any project out there, I'll go get a

11 sample for you. If they put me in jail, fine. "Call

12 channel 7." That what I told the - - the person over

13 at MIT who was in charge of their environmental people.

14 She wanted me in jail. I said "That's fine. Call the

15 news. Call channel 7. I have no problem with that."

16 Just to sum up, again, I'm -- I'm really

17 worried about the PCBs. If they're hot, it's a tough

18 issue. They kids are in schools. It's not going to

19 change. It's deteriorating. I can show you buildings

20 in Boston that have been made into research labs. One

21 of the biggest hits that I ever got myself was 126,000

22 parts per million, and believe it or not, that's a

23 building owned by Harvard University, the reproductive

24 biology building. What does that tell you? What kind

25 of samples do they have going in there with PCBs
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1 floating around?

2 I also had a few of my coparts -- my, my

3 partners in crime come to my house, and I had a nurse

4 come from Harvard University, and they took blood

5 samples. The first time we ever did that. I would

6 have liked to have gotten more, but someone -- one of

7 the guys that came over mentioned something, and it

8 went right up the ladder the union, and that's a no-no.

9 There's all kinds of privacy laws, but no one says

10 anything about their kids having problems. We kind of

11 stick to ourselves. We don't mention things like that,

12 school problems or this problem or that problem or low

13 sperm count, guys who try to have kids and can't. This

14 is what PCB cause, and if I have to be a voice for a

15 lot of people, then that's what I'll be. I guess

16 that's it.

17 MR. SCHREIBER: Thank you very much. Thank

18 you again. Great.

19 Our next speaker is Gigi Gazon, New York City PCB

20 Free Schools Coalition.

21 MR. WEYMOUTH: (off mic) See, I'm a

22 construction worker. I'm sorry. That building, by the

23 way, what was gutted was (inaudible) three months --

24 MS. GAZON: Okay.

25 MR. WEYMOUTH: -- it's rented by MIT
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1 from (inaudible) PCBs, and they caused (inaudible).

2 That's why the big poohah (ph) on the building by the

3 way. We had nine buildings in that area, nine, right.

4 MR. SCHREIBER: Thanks again. Ms. Gazon.

5 MS. GAZON: Hi, good afternoon. How ya'll

6 holding up? Okay? I'm going to be brief, but good

7 afternoon. My name is Gigi Gazon, and I'm a community

8 organizer in the Environmental Justice Program at New

9 York Lawyers for the Public Interest. My colleague

10 Miranda Massey spoke earlier, explained a little bit

11 about who we are and what we do, so I'll refrain from

12 doing that, but I'm here today to provide a statement

13 on behalf of a coalition we work with called the New

14 York City PCB Schools Coalition, who are concerned in

15 particular with the proposed rulemaking as it relates

16 to PCB- contaminated caulk, which you've heard a lot

17 about today. The members of the coalition are

18 concerned citizen and parents who could not be here

19 today during business hours because of work or because

20 they're caring for their children or both in a lot of

21 cases. They're disappointed that the meetings were

22 scheduled during the workday and with such little

23 notice as to undermine public participation.

24 The members of the coalition, however, have a

25 high interest in this issue, and so today they have
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1 asked me to read a statement prepared by Angelique

2 Kotar (ph) and Mike McCabe, who are members of the

3 coalition, and are parents of two daughters who attend

4 school in the Bronx as a matter of fact near Co-op City

5 that George mentioned earlier.

6 "To the distinguished members of this panel,

7 one of our daughters attends Public School 153, a

8 school that has been found to have very high levels of

9 PCB. We also represent a coalition of concerned

10 citizens who are working to have all PCB-contaminated

11 caulk removed from New York City public schools. Among

12 our members is a parent who sued the Department of

13 Education in an effort to get them to address this

14 issue in a responsible manner. She, like the rest of

15 us, is deeply concerned for the well-being of her

16 children and is alarmed by the fact that here children

17 attend a school in which such a severe toxin is

18 present.

19 Recently, the New York City Department of

20 Education entered into a settlement with the EPA to

21 conduct a pilot program at several New York City public

22 schools to study the PCB-exposure risk to students and

23 to come up with a remediation plan for the entire

24 city."

25 And I'll echo what's been said before that
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1 while we consider it to be inadequate because they call

2 for air tests, and we would prefer that they test the

3 caulk. We do appreciate that steps are being taken at

4 least to admit that there is an issue and something

5 needs to be done about it.

6 And we're surprised and very concerned at

7 this time, especially on the heels of the settlement,

8 that the EPA would consider lowering or possibly

9 eliminating the protections of the current regulatory

10 threshold for PCB contaminated caulk. It is

11 scientifically undisputed that PCBs pose a significant

12 risk to human health, especially that of children, a

13 fact that has been regularly acknowledged by the EPA

14 itself.

15 PCBs were banned in 1978 as, quote, toxic and

16 persistent chemicals, end quote. Under the EPA's

17 current regulatory framework, PCBs at levels greater

18 than 50 ppm, and again, quote, presented unreasonable

19 risk to injury and health, end quote. And caulk

20 containing more than 50 ppm PCBs must be removed,

21 according to the EPA. So scientists, government

22 officials and society all know the risks associated

23 with exposure to PCBs, and why at this time would the

24 EPA consider lowering or eliminating the current level

25 of protections for PCB contaminated caulk.
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1 The timing of the decision couldn't be more

2 suspect, and given that there's been no recent change

3 in the science around the issue, the members of this

4 coalition can't help but wonder if the EPA has economic

5 rather than scientific reasons for considering the

6 proposed action. Members of our community are already

7 exposed to many different toxins, pollution from

8 proximity to traffic clogged highways and contaminated

9 brown fields, in addition to other noxious threats from

10 industrial uses.

11 And we know that we speak for other coalition

12 members whose children attend schools containing PCB

13 contaminated caulk. And we ask you to avoid making any

14 changes to the current threshold of PCBs in caulk until

15 we have more information about the risks, and until all

16 the planned studies are completed. There are reports

17 released in fields almost daily documenting the harmful

18 health effects of chronic low-level exposure to PCBs.

19 The information contained in those reports

20 that PCBs disrupt the immune system, that they affect

21 our children's ability to learn, that they are known to

22 affect the reproductive system, and that they are known

23 carcinogen, has left many parents in our communities

24 frightened at the prospect that the EPA will eliminate

25 the current protections. Think for a moment about the
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1 detrimental impact that these chemicals can have on the

2 bodies of developing children, and then rather than

3 considering the economic challenges of the present, we

4 urge you instead to consider the future cost to our

5 children.

6 By eliminating the protections, you will be

7 putting their long-term health and their quality of

8 life at risk. The New York City PCB Preschools

9 Coalition calls for the EPA to keep the current

10 protections as they relate to PCBs in caulk, and to

11 aggressively enforce the current regulations. The

12 health of our children is at stake, and any change that

13 would lead to the continued exposure to PCBs will put

14 all of our futures at risk. Sincerely, Michael McCabe

15 and Angelique Cotar (ph) on behalf of the New York City

16 Coalition for PCB Preschools. Thank you very much.

17 MR. SCHREIBER: Thank you. The next speaker

18 is Daniel Lefkowitz, private citizen.

19 MR. LEFKOWITZ: Can you hear me? Okay. I'm

20 just going to talk briefly about PCBs and my

21 relationship and my history with this whole issue. In

22 about 2004 or 2005 I read Bob -- Dr. Bob Herrig's study

23 up in Harvard where he took 24 samples, or actually

24 George took 24 samples and a third of them came back

25 contaminated. So at that time my sons -- I was living
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1 in Yorktown Heights and my son was in the (inaudible)

2 elementary school, and was curious.

3 I said, well, my son's school was built in

4 1969 and the windows were removed about a year ago. So

5 could it -- could it have been contaminated with

6 caulking. So I called the region two and I was told go

7 around and find a piece of caulking, and that's what I

8 did. I walked around the school and there was caulking

9 all over the place. The contractors left the stuff on

10 the ground. I picked up a piece and I sampled it. It

11 came up -- I forgot the thousands of PPM, so I sent the

12 results over to the Westchester County Health

13 Department and they contacted the school and they told

14 the school go ahead and just pick up the rest of the

15 caulking.

16 So I said to the health department, what

17 about the soil. He said no problem with the soil. You

18 don't have to worry about it. So I didn't believe him.

19 So I went back. I grabbed some soil and it came out

20 280 ppm. New York State has a cleanup buffer, I believe

21 it's one part per million. So then all of a sudden the

22 health department came in. They started doing sampling

23 and they found the whole soil was contaminated.

24 They sampled the building and the caulking,

25 all over the school was contaminated, and so you figure
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1 the EPA was involved, the health department of New York

2 State and sure enough they had to clean up the caulking

3 from the buildings, clean up the soil, and it was

4 estimated it was several hundred thousand dollars. And

5 -- and New York State said that they would kick in,

6 maybe to pay at least 50% of it, they would reimburse

7 the school. So from that point on I figured, well, you

8 know what, if it happened in my son's school, it's

9 happening everywhere else.

10 So I started to go around with George Rambis,

11 started sampling other schools and we found that there

12 were a lot of other schools that were contaminated. And

13 so I figured, well, the only way to get this, you know,

14 get this word out is to either go to the press, and I

15 was in the New York Times twice on this issue. I met

16 with Assemblyman DiNapoli at the time who is now a

17 state, I believe it's the controller. I met with him

18 and has office, with his personnel several times. We

19 met with the state health department. We met with the

20 state education department about this whole issue, and

21 that was kind of the thing that started getting the

22 ball rolling as far as getting New York State's

23 protocol and guidelines.

24 And so from that point on I created a

25 website, PCBinschools.org to get the word out to the
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1 public and to the -- all the stakeholders, politicians,

2 the legislators, the school administrators and the

3 thing about my website is to get -- to make this whole

4 PCB issue mandatory. I want to get mandatory testing.

5 That's what's lacking in this whole thing. It's one

6 thing to know that if you find it in caulking and if

7 it's above 50 ppm, under the law you've got to remove

8 it because it's unauthorized use, but there is no --

9 nothing in the law that states that you have to go and

10 test for it, and that's the major issue because no one

11 is going to test for it.

12 And that's why George and I go around and we

13 look at buildings. And that was one of the impetus for

14 the Daily News investigation. George and I went down

15 to a number of schools in the Bronx and we tested a

16 number of schools. We saw a number of schools were

17 hot. We contacted the Daily News, and from that point

18 on the Daily News did their investigative studies. So

19 what's the -- so what's the major issue here is that if

20 you look at the building across the street, you're

21 looking at thousands -- thousands of feet of stockpile

22 of caulking and possibly paint, and these are long-term

23 emitters of PCBs, and my contention is that this stuff,

24 there should be mandatory testing.

25 Maybe not so much in public buildings, but in
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1 schools because that's where children are and they're

2 the most sensitive to this chemical, plus it's

3 mandatory that kids attend school, and they have a

4 right to know, and parents have a right to know whether

5 their children will even stand for being submitted or

6 being exposed to these chemicals. So as far as

7 rulemaking, I'm submitting to the EPA that you put in

8 your rulemaking mandatory testing for PCBs in schools

9 because this way we would have a database throughout

10 the whole United States. We would know how many

11 schools are affected by it, and the EPA should be

12 working with the CDC and also the department of health

13 to take blood (inaudible). I understand the EPA is an

14 environmental agency and they don't deal with blood,

15 and that's where the other governmental agencies like

16 the CDC will have to start, step in and do blood

17 (inaudible) because otherwise I understand that it's a

18 great step that the EPA and the Department of Education

19 during the study with the five schools, but we know

20 that's not enough and we need to do a cross section

21 throughout the whole United States, get a history of --

22 get a history of children, the intake, and take blood

23 studies, do air studies, and that's the only way we're

24 ever going to make a final determination about, you

25 know, the situation -- the situation here in the United
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1 States.

2 And if you look at this whole thing globally

3 you have with the Helsinki convention, where the whole

4 world is moving towards eliminating PCBs. And they're

5 using the 50 ppm. And my -- my recommendation, and I

6 strongly suggest that the EPA stick with the 50 parts -

7 - ppm's, or even reduce it, because if you reduce it,

8 now you're going to start to eliminate more stockpile

9 of contaminated material and I think that's it.

10 MR. SCHREIBER: Okay. Our next speaker is

11 Richard Barr, Chair of External Affairs Committee,

12 Parent Association, Bronx High School, School of

13 Science.

14 MR. BARR: Good afternoon. I'm speaking on

15 behalf of the executive board of the parents

16 association, the Bronx High School of Science, and we

17 have informed the administration of the school of what

18 I was going to come here to say, and they're okay with

19 it, but I'm speaking for the parents at this point.

20 Bronx Science is a school that was built during the

21 period in question, in 1950 to 1978.

22 It's got almost 3000 students and hundreds of

23 adults all moving around in close proximity within the

24 building. To the best of our information, it's never

25 been tested as to whether there were PCBs in the caulk.
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1 It is our information that from the caulking used

2 during that period in New York City, some -- some

3 places will have it, some not. We don't know which

4 category our school is in. I mentioned to the

5 administration this hearing and was told, well, we had

6 the windows replaced 10 years ago, and I think that

7 that's interesting because in terms of what's not known

8 out there, here you have a school under the impression

9 that that -- if there is a problem, and we don't know

10 if there is or not, that that would have taken care of

11 it.

12 When testimony right here today from PS 53 in

13 Staten Island was that the replacement of the windows

14 increased the existing problem, and the testimony from

15 PS 199, and by the way, until this year, that building

16 in Manhattan had an elementary school on the lower two

17 floors and a middle school on the top floor, and my

18 daughter who is now at Bronx Science was in that middle

19 school until 2007, so during the course of this, and I

20 know well Linda Rosenthal, the assemblywoman who

21 submitted the bill in the state assembly in response to

22 what was found there, but we heard in the discussion

23 about PS 199 that an inadequate job of replacing the

24 windows and a subsequent remediation in the face of

25 that inadequate job, still left unacceptable levels of
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1 PCBs around. So there's a lot out there that isn't

2 known about which schools had PCBs, which did not, and

3 which ones have problems with the PCB exposure and

4 which don't.

5 And the fact that the DOE has agreed with EPA

6 to test five schools, as other people have said, is the

7 tip of the iceberg. And our contention is that while

8 we don't know how many schools have a problem, and how

9 big the problem is, at minimum, the current standards

10 should be kept in place, certainly not relaxed. And we

11 also know that even if a good job was done, and if we

12 have PCBs and a good job was done in replacing those

13 windows, they might still exist in door frames. That

14 might still exist in fluorescent light fixtures.

15 So this is not the time when so little is

16 known about so many schools and whether they have a

17 problem or not to relax the standards. Now, I am going

18 to now speak for myself, and what I'm going to say

19 rather than for the whole body. And what I'm going to

20 say is speculative, but I also feel that not only does

21 the EPA need to push the New York City Department of

22 Education to test far more schools, but it may also

23 ultimately, if problems are found, it may need to hold

24 that agency's feet to the fire, and this is the

25 speculative part, but it's something that I find very
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1 troubling and I'm going to mention it.

2 Love Canal was mentioned earlier. Now, I

3 worked in the state attorney general's office for

4 several years and I know that the two probably longest

5 lasting environmental issues in terms of cleanup that

6 our environmental protection bureau was dealing with

7 were Love Canal and trying to get the General Electric

8 company to clean up the PCBs that they had dumped into

9 the upper Hudson River. So some years ago I was

10 watching 60 Minutes and the then CEO of General

11 Electric, Jack Welch, was asked by the host, well, the

12 EPA is after you. The New York State Department of

13 Environmental Conservation is after you to clean them

14 up. Are you going to clean them up? His response was

15 bring me a glass of water laced with PCBs. I'll drink

16 it right in front of you right now.

17 So to my mind, this is a white-collar

18 criminal. Well, he left GE and later on Joe Klein

19 became chancellor of the New York City Department of

20 Education. Having been a bureau chief in the Justice

21 Department during part of the period when EPA was after

22 GE to do this cleanup, so he could not be unaware of

23 it, and yet when he chose to start a leadership academy

24 to train would-be principals for New York City public

25 schools, who did he put in charge of it, Jack Welch. So
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1 again, this is speculative, but to me if this is an

2 indication of how seriously the DOE might take the

3 issue of PCBs and whether they're a problem or not, I

4 say the EPA has got to keep holding their feet to the

5 fire and can't count on them to do the right thing

6 should problems be detected, without pressure. So

7 thank you.

8 MR. SCHREIBER: Thanks. Our next speaker is

9 Maureen LaMar, New York Committee for Occupational

10 Safety and Health.

11 MS. LAMAR: Hi. I am the Associate Director

12 of the New York Committee of Occupational Safety and

13 Health or NYCOSH and today I'm presenting an

14 abbreviated -- I'm going to read. Forgive me for that,

15 but I'm going to read an abbreviated version of the

16 comments of David Newman, who is NYCOSH's industrial

17 hygienist. The unabridged version has been submitted

18 electronically and I have hard copies over there if

19 anybody needs one. NYCOSG appreciates this opportunity

20 to comment on EPA's advanced rulemaking notice. NYCOSH

21 works closely on environmental and occupational safety

22 and health issues with unions that represent teachers,

23 school maintenance workers and contractors, all of whom

24 are potentially exposed to PCB containing caulks and

25 paint. That's why I really appreciated your
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1 presentation, George.

2 In addition, we are actively involved in

3 green initiatives, including working with -- working

4 with and providing occupational safety and health

5 training to workers involved in weatherization

6 projects. These workers are likely to disturb window

7 caulk, which may contain PCBs resulting in potential

8 occupational exposure and then potential contamination

9 of the habitable spaces in which they work. In

10 addition, NYCOSH has provided technical assistance to

11 New York City Department of Environmental Protection

12 regarding hazard assessment and remediation of PCB

13 caulk and transform PCBs and other contaminants at a

14 New York City wastewater treatment plant.

15 Our comments will be limited to the proposed

16 reassessment of PCB containing caulks and paints. The

17 EPA requests input on whether the use of PCBs at

18 concentrations of 50 ppm or greater in caulks currently

19 unauthorized should be authorized, and on whether the

20 50 ppm level that defines excluding PCB products, that

21 is excluding from regulation, to be changed. The only

22 reason the EPA gives for these possible revisions is

23 that the use of PCBs in caulk may be widespread and may

24 -- may be an undue burden for schools.

25 Many people have made this point, but let me
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1 continue. NYCOSH is disturbed that possible changes to

2 environmental regulations appear to be driven solely by

3 economic factors. We are concerned that no reasons

4 protective of environmental or public health are cited.

5 While we acknowledge the reality of economic factors,

6 we believe there are currently no valid scientific

7 reasons for weakening or eliminating environmental

8 regulations pertaining to unauthorized uses of PCB

9 products and/or non-totally enclosed PCB building

10 materials.

11 This is a problem going last. All of this

12 has been said before. We agree with many of the

13 speakers. NYCOSH urges EPA not to revise PCB

14 regulations based solely or primarily on economic

15 factors. We object to regulatory revision in the

16 absence of science-based evidence that we need to do

17 so. When EPA began to address the issue of PCB caulk

18 in schools, the agency referenced 40 CFR 761.20 which

19 states, quote, no persons may use any PCB or any PCB

20 item regardless of concentration, in any manner, other

21 than in a totally enclosed manner unless authorized

22 under the 761.30.

23 Total enclosed manner means any manner that

24 will ensure no exposure of human beings or the

25 environment to any concentration of PCBs. And possibly
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1 its first public statement on PCB caulk in schools, EPA

2 wrote in 2005, the use of PCBs in caulking has never

3 been authorized by the EPA. The placement of such

4 materials predates the enactment of the toxic

5 substances control act and its use today is not

6 authorized. Because it is illegal and a potential for

7 exposure may be significant, PCB containing caulk must

8 be removed upon discovery. EPA reiterated its position

9 in 2007. Any non-totally enclosed use not specifically

10 authorized under 761.30 is prohibited. The use of PCBs

11 in caulk is not an authorized use and thus is a

12 violation of section CE of Testa (ph). Yet in 2009 EPA

13 retreated from its -- retreated, excuse me, retreated

14 from its protective stance, quote, caulk that contains

15 PCBs at greater than 50 ppm is not authorized for

16 continued use and must be removed.

17 You are not required to remove caulk

18 containing PCB levels at levels below 50 ppm. Excluding

19 PCB products, that is products excluded from

20 regulation, are defined as, quote, PCB materials which

21 appear at concentrations less than 50 ppm. However,

22 all examples of excluded PCB products listed in 761.3

23 are products that have become contaminated with PCBs,

24 not products manufactured with PCBs as intentional

25 ingredients. Because some caulks and paints were
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1 manufactured with the deliberate inclusion of PCBs for

2 their plasticizing properties, we believe they should

3 not be considered excluded products. That is they

4 should not be excluded from regulation. NYCOSH urges

5 EPA to revert to its original position that in place

6 PCB caulks, regardless of concentration, should be

7 considered unauthorized.

8 With regard to health risks from exposure to

9 PCB caulks, EPA has given insufficient consideration to

10 the populations with potentially the highest exposures

11 and risks, the maintenance workers and contractors who

12 maintain and replace PCB building materials and the

13 winterization workers who retrofit older buildings to

14 increase energy efficiency under federal stimulus

15 programs.

16 These disturbance activities could

17 significantly accelerate the release of PCBs into the

18 air where they are available for inadvertent inhalation

19 as well as to (inaudible) them throughout the

20 environment. Reliance on occupational standards may

21 not be adequately protective of workers engaged in

22 disturbance of PCB building materials. These standards

23 in general are promulgated for application to

24 industrial workplaces and are intended to protect

25 workers who are trained to be fully aware of the
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1 hazards of the occupational environment who may have

2 specific training in and access to respirators and/or

3 protective clothing and who may actively participate in

4 medical monitoring programs.

5 Our experience is that employers of school

6 maintenance workers and contractors, and the

7 winterization workers do not conduct PCB focus job

8 hazard exposure assessments and do not provide training

9 on PCB hazards, safe work practices and use of personal

10 protective equipment. Given that OSHA has no airborne

11 permissible exposure limits and that NIOSH recommended

12 limits are unenforceable, and would provide only half

13 as much protection as EPA's public health level for

14 adults, it is essential that EPA consider occupational

15 exposure and occupational health as key criteria as it

16 evaluates whether to revise the regulations pertaining

17 to PCB building materials.

18 EPA must focus on the work population, the

19 work tasks most likely to have the greatest

20 opportunities for exposure, risk and substance release.

21 Protection of the most exposed workers by eliminating

22 or reducing the introduction of PCB contaminants into

23 the -- into the indoor environment may be the most

24 effective method for mitigating other human and

25 environmental exposures. In this sense, the most
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1 exposed workers serve as the canaries for the public

2 health of the community at large. Such an approach is

3 not unusual.

4 EPA's managing asbestos in place has

5 developed and maintained a building asbestos operations

6 and maintenance program utilizes precisely this

7 approach, relying on protection of workers to protect -

8 - excuse me, to protect the public health. In

9 conclusion, NYCOSH urges EPA not to revise regulation

10 for PCBs in caulks and other non-totally enclosed, non11 authorized PCB building materials based solely or

12 primarily on economic factors. We object to regulatory

13 revision in the absence of science-based evidence of a

14 need to do so. NYCOSH urges EPA to revert to its

15 original position that in-place PCB caulks, regardless

16 of concentration, should be considered unauthorized.

17 NYCOSH urges EPA to consider worker exposure

18 scenarios as it assesses whether to revise regulations

19 pertaining to PCB caulks. NYCOSH urges EPA to adopt

20 guidance for comprehensive written O and M programs for

21 in-place PCB building materials. The guidance should

22 be similar to the agency's guides for asbestos O and M

23 programs, and should include, one, sampling of in-place

24 PCB caulks to determine concentration. Two, labeling

25 of in-place PCB caulks. Three, establishment of
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1 science- based action and levels of procedures for

2 removal of PCB building materials. Four, regular area

3 and personal sampling. Five, regular visual inspection

4 of PCB building materials. Six, record-keeping. Seven,

5 training and engineering and administrative controls,

6 safe work practices, and appropriate use of personal

7 protective equipment. Eight, where appropriate

8 training in and provision of proper respirators as per

9 the OSHA respiratory protection standard and last, a

10 program to inform workers, contractors and building

11 occupants where PCB materials are located and to notify

12 them of planned, ongoing disturbance activities. Thank

13 you for this opportunity to present the comments.

14 MR. SCHREIBER: Is Mark Drozdov present?

15 Mark, you're next. Mark is the past president of the

16 American Industrial Hygiene Association.

17 MR. DROZDOV: Good afternoon everybody. I'm

18 here today to speak on behalf of the members of the

19 Industrial Hygiene Association of Metro New York. As a

20 past president of the (inaudible) shelter and along

21 with me is Cassandra Ballinking (ph), and we simply in

22 reviewing the recent documentation wanted to ask a

23 couple of questions on behalf of the membership and the

24 industrial hygienists that we represent. You know, in

25 the course of our daily routine we deal with a lot of
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1 different hazards, and above any hazards is what we do.

2 And we also look at work practices and we're

3 concerned about worker protection, and in reviewing the

4 available documentation and doing the research, we just

5 at times are struggling to reach to other regulations,

6 aside from PCBs, to do our work. Specifically, the

7 awareness training and the training that should be done

8 in anybody working with any hazardous materials. We

9 are wondering if the EPA is considering any kind of

10 training curriculum to recommend, and as well as

11 accessible guidance for what has already been mentioned

12 here for testing and monitor analysis. And the one

13 thing that, you know, Cassandra and I, in dealing with

14 our customers and our, you know, cases, we found

15 deficiencies of studies of showing conclusive evidence

16 of respiratory problems associated in being exposed to

17 PCBs. So those are just a few items that we're going

18 to bring to the surface as part of our American

19 Industrial Hygienist Association, Metro New York

20 chapter. Thank you.

21 MR. KELLOGG: Good afternoon. I

22 have a different story to tell, completely different.

23 My name is Chuck Kellogg. I am the owner of a fourth24 generation business in Waterbury, Connecticut. My

25 daughter is executive vice president and will take it
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1 over, and so it's a long time successful business.

2 In June of 2008, there was a big wind storm

3 in a property right behind our property, not on our

4 property. It came down on our property, landed on the

5 roof, and you know what happened, it spilled PCBs.

6 Connecticut Light and Power reacted very quickly, came

7 and cleaned it up as best they could. The EPA came in.

8 What they found in addition was that this building,

9 which was built in 1954, had never been painted again,

10 was painted in 1954 with a PCB paint, which was very

11 common in those days inside and out. Subsequently over

12 the years, the inside was painted and so forth -- but

13 the outside -- this is in a very industrial area.

14 There's no families around, and they never even painted

15 it.

16 Now we don't have any children or women

17 working there. There's never been anybody who's been

18 sick. We've had the air tested. It's fine. We did it

19 of course because EPA was involved. We had to respond,

20 which we have, so I'm just giving you a summary. There

21 were certainly in the wall, the building, excessive

22 PCBs because it's had never -- never been treated; very

23 high level; 4,000 to $30,000 ppm in some part.

24 So the question was that we had written --

25 there's been no -- no damage, nothing ever been hurt,
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1 no one ever -- we've had people working there for 50

2 years, never any problems. How to respond to that was

3 the question we had to do. I'm not going to give you

4 all the -- all the gory details. In effect, it's a

5 nonuse for a nonliquid PCB. Of course, we know that.

6 So what did we do?

7 Well, as (inaudible) say he just knocked the

8 building down. That's obviously what cost over $1

9 million. It would put 10 people out of work. It would

10 disrupt our business, and it doesn't make -- it doesn't

11 make any great sense to us. I'm just going to leave

12 give you a summarize.

13 We believe that the EPA should authorize

14 continued use of nonliquid PCBs in situations such as

15 ours where it could be demonstrated that such use will

16 not pose an unreasonable risk of health or the

17 environment. We are a heavily developed industrial

18 setting, and so we have proposed that we clean up

19 whatever fell on the ground. We would want to --

20 propose removing loose, degraded paint from exposed

21 exterior and interior walls; and following removal of

22 loose, degraded paint, we're proposing to encapsulate

23 these surfaces with two solid-resistance and water24 repellent coatings of contrasting colors. We propose

25 inspection monitoring and maintenance, plus to be
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111

1 maintained to ensure the further postmitigation

2 condition will continue, not to present unreasonable

3 risk of injury to other people.

4 I'm just telling you there are some

5 conditions under which nonliquid PCB in certain uses --

6 I'd say it shouldn't be promoted, but is should be if

7 handled correctly not go out to destroy a business

8 that's been in business for 150 years, what this would

9 do. So I'm -- by the way, this is where -- we are

10 submitting this Region 1 because that's where it

11 involves.

12 And just a couple of points. EPA has

13 indicated that TSCA regulations do not currently allow

14 for continued use of TSCA-regulated nonliquid PCBs,

15 which we understand, such as paint or caulk. This is

16 not caulk. We understand that PCB has proposed to

17 authorized such continued use in its December 1994

18 proposed rulemaking where EPA indicated that premature

19 removal of media containing PCBs could only be achieved

20 with great difficulty and enormous expense given the

21 extraordinary effort that are required to removed PCBs.

22 The conditions proposed by EPA for continued use of

23 these items' removal upon evidence of deterioration on

24 insulation or release control or encapsulation would

25 ensure no unreasonable risk from exposure to PCB. This
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1 was in 1994.

2 In 1998, EPA deferred final regulatory action

3 on use of authorization for nonliquid PCBs. EPA

4 indicated that it intended to address this issue in

5 further rulemaking but needed more time and information

6 to evaluate the potential risk of exposure from PCBs

7 that might be associated with such existing nonliquid

8 PCBs.

9 In the fall of 2009, EPA published some

10 useful documents addressing nonliquid PCBs in caulk and

11 acknowledged its understanding, unfortunately, of high

12 levels of are of PCBs are present in many building and

13 facilities constructed prior to the PCB ban including

14 most recently some schools.

15 EPA Administrator Jackson also state "We are

16 concerned about potential risk associated with exposure

17 to these PCB. We've recommended a practical, common

18 sense step to reduce this exposure as we improve our

19 understanding of the science." EPA continued to

20 recognized that resources are sometimes not available

21 to immediately remove all nonliquid PCBs and that

22 interim methods are sometimes need to reduce human

23 exposure to PCB during the time before such nonliquid

24 PCBs are removed. With this new guidance, it's

25 applicable to nonliquid PCBs in schools where small
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1 children is not explicitly pertinent to nonliquid PCBs,

2 and points to industrial facilities such as ours. And

3 as many of you know, there is a lot of the paints that

4 are involved in Navy ships and nuclear plants and so

5 on.

6 There are other points of view where

7 nonliquid PCBs can be contained and remediated without

8 destroying businesses. Thank you.

9 (Applause)

10 MR. SCHREIBER: So that concludes the

11 preregistered speakers list. If there is anyone who

12 did not have a chance to talk yet but wanted to make a

13 comment, they are invited now. Otherwise, unless

14 anyone else from -- would like to make a comment, then

15 I guess we'll adjourn. Maria. Thank you.

16

17 * * * * *

18

19

20

21

22

23

24

25
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1 CERTIFICATE

2 STATE OF NEW YORK )

3 )ss.

4 COUNTY OF NEW YORK)

5 I, ELIZABETH WILLESKI, a Registered Professional

6 Reporter and Notary Public within and for the State of

7 New York, do hereby certify:

8 That I am not related to any of the parties to

9 this action by blood or marriage and that I am in no

10 way interested in the outcome of this matter.

11 IN WITNESS WHEREOF, I have hereunto set my hand

12 this ___ day of _____________ 2010.

13

14 _________________

15 ELIZABETH A. WILLESKI

16 My commission expires: February 27, 2014

17

18

19

20

21

22

23

24

25
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1 I N D E X

2

3 SPEAKER PAGE

4

5 Dan Craft 4

6 Tom Simons 6

7 Jim Roewer 10

8 Mary Davis 18

9 Aurelia Greene 26

10 Jonathan Davis 31

11 Valerie Watnick 37

12 Miranda Massey 41

13 Patricia Donegan 46

14 Ann Casey 60

15 George Weymouth 71

16 Gigi Gazon 86

17 Daniel Lefkowitz 91

18 Richard Barr 96

19 Maureen LaMar 100

20 Mark Drozdov 107

21 Charles Kellogg 108

22

23 * * * * *

24

25
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$

$1 110:8

$10 16:22

$100 82:11

$150 55:24

$19 80:17

$2.6 21:23

$270 16:21

$30,000 109:23

$6 16:12 22:24

$6.4 16:9

0

07 52:21

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1

1 111:10

1% 25:4

1,600 69:8

1,740 72:1

1.4 7:3

1.5 7:3

1:00 1:10

10 30:20 35:5 52:18

55:4 64:17

69:18,20 71:6,7

78:16 97:6 110:9

115:7

100 10:17 64:10

115:19

107 115:20

108 115:21

12 30:21

1240 82:6

1254 72:2

126,000 85:21

1260 72:2 82:6

13-year-old 61:7

14 82:6

14th 2:3

15 78:16 82:5

150 111:8

153 88:7

18 115:8

18,000 64:20,22

1929 7:2

1950 34:22 96:21

1954 109:9,10

1960 68:9

1960s 68:14

1966 46:24

1968 34:1

1969 92:4

197,000 22:4

1970s 38:25 68:14

1977 7:3

1978 63:22 68:9

89:15 96:21

1979 22:17 32:13

39:3 43:15 46:1

1980 34:22

1982 22:24 23:11

25:10,15,19

199 33:25 34:6

38:2,6,13 39:22

58:21 97:15,23

1994 111:17 112:1

1998 112:2

1st 34:23,24

2

2 1:12 2:8 4:5

2% 25:6

2,000 80:25

20 35:1 84:2

200 20:1 64:21

2000 9:5

2001 19:1

2002 72:23

2003 72:23

2004 91:22

2005 91:22 103:2

2006 46:19 49:6

69:7

2007 50:15 53:17

97:19 103:9

2008 21:13 25:2,5

33:23 54:20 56:7

109:2

2009 34:20 39:14

40:1 103:12

112:9

2010 1:9 4:16 5:8

16:14 27:19 35:6

114:12

2011 10:9 34:24

2012 34:23

2014 114:16

2020 2:3

209 6:23

22 60:20 61:3 68:6

22201 2:3

225 55:16

22s 9:24

24 29:24 81:4

91:23,24

25 14:17 61:15 72:1

26 115:9

26,500 78:5

27 114:16

2735 1:13

27th 1:13

280 92:20

290 1:12

2B 8:11

2nd 49:3 56:25

3

3 30:21 71:6

3,356 25:5

3:00 5:19

30 4:23 10:20 11:10

16:7 19:7 21:2

55:19 64:6,15

66:10 67:2

69:13,22 77:7

30,000 72:1

30+ 69:12

3000 96:22

31 115:10

31,149 25:3

31st 39:3

31-year 18:22

36,000 82:3

37 73:23 115:11

3rd 46:20,22

4

4 115:5

4,000 109:23

40 9:17,19 46:23

47:15 71:13

102:18

400 57:11

41 115:12

46 115:13

49 43:17

5

5 67:6

5.2 24:5

50 6:24 9:19 14:15
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27:24 30:12

32:4,7,12 33:13

34:24 36:4,22

38:8,10,25 39:5

40:3 42:14,19

43:10,16 56:24

61:16 64:8

66:10,13,23 67:5

69:9,13 89:18,20

94:7 96:5,6

101:18,20

103:15,18,21

110:1

50% 93:6

50,000 71:21 80:16

500 25:4,7 39:5

64:10

51 43:17

53 46:20 58:20

97:12

560 2:3

6

6 5:15 115:6

60 51:19 99:10

115:14

62 21:22

6E 8:2,11

6th 5:8

7

7 1:9 85:12,15

70 69:8

703)312-7831 2:4

70s 7:17 43:4 73:5

71 115:15

761.20 102:18

761.3 103:22

761.30 102:22

103:10

79,100 57:15

7th 4:16 5:4,13

27:19

8

80 51:19

800 51:17

84 8:14

86 115:16

9

9 64:25

90 11:6 56:10,14,15

79:22

900 63:1 67:6

90s 61:18 72:4

91 115:17

96 115:18

96,000 21:15

994 55:14

A

A-7556(a 34:25

abated 80:22,23

abatement 77:12

81:22

abbreviated

100:14,15

ABC 54:22

abdication 36:13

ability 67:10 90:21

able 20:18

57:9,16,17 66:20

abnormalities

43:25

absence 102:16

106:13

absolutely 42:18

45:12

absorbed 67:23

absorption 33:7

abused 67:16

AC 47:13

academic 38:24

academy 99:23

accelerate 104:17

accelerated 12:7

acceptable 39:18

accepting 5:7

access 105:2

accessible 21:6

108:11

accomplished 12:6

22:18

accomplishment

35:9

accomplishments

14:24

according 32:1

89:21

accountability

70:17

accurate 20:9

57:3,6

achievable

13:18,21 14:22

achieve 17:22

achieved 111:19

acknowledge 27:15

102:5

acknowledged

89:13 112:11

acrid 78:11,12

across 12:14 13:15

22:21 94:20

ACs 48:10

act 6:16 8:3 24:9

27:8 34:3 103:5

Acting 2:6 4:3

action 90:6 107:1

112:2 114:9

actions 27:14 30:11

activator 73:10

active 35:14 48:12

actively 81:21

101:2 105:3

activist 63:20

activists 37:6

activities 8:16

10:16 104:16

107:12

actual 29:7

actually 9:10 66:17

91:23

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added 42:6,9 47:4

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14:20,25 23:17

26:2 32:23 38:12

90:9 101:2,10

109:8

additional 33:8

35:1

additionally 33:1

add-on 61:23

address 5:13 17:13

26:23 27:9 31:6

88:13 102:17

112:4

addressed 29:23

45:8

addressing 112:10

adequate 19:18

45:11

adequately 29:25

104:21

adhere 75:12,17

adhesive 79:19,21

adjacent 81:25

adjourn 113:15
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adjust 41:2

administer 19:12

administration

31:13 36:13

50:24 96:17 97:5

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107:5

Administrator 27:3

41:21 112:15

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94:2

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96:23 105:14

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45:21 64:17

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5:1,17 6:3 11:5

17:14 19:15

27:18 29:14,24

30:9,11,16 32:1

41:1,23 42:12

44:18 100:20

advocate 38:24

AEP 18:23

19:1,14,23 20:2

21:3,7,9,10,16

22:9 23:6,21 24:7

25:2,8,22

AEP's 22:4,15 24:5

26:2

Affairs 3:15 96:11

affect 67:18

90:20,22

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95:11

affecting 76:21

affordable 14:21

afraid 80:6

afternoon 4:5,20

18:17 26:19,20

37:23 41:12,25

60:10 87:5,7

96:14 107:17

108:21

against 21:24

44:16,23

age 12:19 25:21

40:12 51:21

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30:22 95:15

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10:21 11:5 15:12

17:14 20:9,22

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28:5,10,18 30:19

32:4 36:18 42:6

45:4,6 46:2 60:15

95:14 102:18

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98:24 106:22

ages 19:23

aggression 33:2

aggressive 11:14

aggressively 91:11

ago 16:7 23:2,15

41:20 61:4 66:10

69:13 71:10 92:4

97:6 99:9

agreed 23:15 35:7

53:25 56:22

69:14 98:5

agreement 27:11

45:9

ahead 12:18 71:6

74:17 92:14

air 29:4 35:14,20

39:18,20,22,25

40:6,7,8 43:1

48:25 51:7,9,24

52:22 54:1

55:7,10,13,19,22

56:3,5,9,10,14,15

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58:13,22 64:23

66:14,18,20

68:4,24 70:24

76:19 79:24,25

84:7 89:2 95:23

104:18 109:18

airborne 76:20

105:10

alarmed 88:16

Albacar 72:3

Albans 21:17

Albany 31:25 60:19

allotted 11:7

allow 53:25 111:13

allowable 36:18

allowed 8:24 35:20

39:1 57:21 78:13

allowing 6:18

allows 8:11

alone 25:24 53:2

already 11:14,25

12:5 13:6 19:20

20:4,24 45:7 90:6

108:11

already-conclusive

33:12

am 18:18,24

38:1,12,13,15

39:9 59:10 98:17

100:11 108:23

114:8,9

amazing 76:24 79:8

amend 30:11,14

amending 29:2

30:12

Amens 21:17

American 2:18

3:21 18:19 26:12

107:16 108:18

among 14:9 27:10

41:16 88:11

amount 17:11

49:24 51:14

57:21 72:18 82:7

83:16,17

AMPACT 24:14

ample 5:22

analyses 64:23

analysis 16:25

26:10 36:15

60:22 61:2

64:14,24

66:17,22,23,24

78:4 108:12

Analytical 3:7

64:18

analyzed 78:4

79:22

and/or 29:9 102:9

105:2

Angelique 88:1

91:15

angst 60:12

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Ann 3:7 41:4

60:5,11 81:16

115:14

Anniversary 46:24

announce 45:23

announced

45:13,14

announcement

35:6

ANPRM 19:25

answer 5:3 54:17

57:25 66:25

anxiety 44:8

anxious 52:3

anybody 100:19
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108:8 109:17

anyone 53:17 58:6

60:9 113:11,14

anything 52:12

54:12 56:20 58:8

59:7 70:4,13 71:1

75:5 78:10

80:4,25 84:21

86:10

anywhere 53:20

81:8

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apologize 79:14

apologized 79:1,3,5

81:1

apologizing 79:15

appalled 32:10

apparatus 78:14

apparent 28:1

Apparently 56:14

appear 102:2

103:21

appears 28:15

42:23

applaud 28:18

Applause 31:17

37:20 41:7 46:9

60:4 71:4 113:9

applicable 112:25

application 104:23

applications 7:9

applied 83:22

appreciate 4:19

10:23 11:8 89:3

appreciated 100:25

appreciates 100:19

approach 12:3

47:20 106:2,7

appropriate 17:15

29:11 107:6,7

approximately

16:21 21:23

71:21

April 4:16 5:4,13

27:19 34:20

54:20 56:7

apt 80:7

aptly 23:4

arbitrary 8:25 13:4

architects 73:15

area 63:6 69:5 85:7

87:3 107:2

109:13

arena 59:10

aren't 78:13

arguments 36:11

Arizona 47:1

Arlington 2:3

arms 79:10

array 20:1,6

arrive 53:5

art 29:6

article 38:16,20

54:19 55:9

articles 20:17

21:4,5

asbestos 78:6,7,8,9

79:23

80:4,5,8,9,18,22

83:16 84:4,8,13

106:4,5,22

aside 33:11 108:6

aspects 19:7,12

42:11

assembly 2:22

31:20,22 32:8

33:21,25

34:19,25

35:8,10,13,24

36:1,20 37:15

97:21

Assemblyman

93:16

assemblywoman

97:20

assess 9:5

assesses 106:18

assessing 35:3

36:24 65:18

assessment 61:25

101:12

assessments 105:8

assist 4:20

assistance 2:8 4:5

101:10

Associate 2:24

100:11

associated 15:20

16:8 36:7 89:22

108:16 112:7,16

association 3:22

10:16 14:13,16

17:21 19:4

96:12,16

107:16,19 108:19

associations 10:18

assumed 20:16

22:13 51:10

assumes 20:15

assuming 24:22

assumption 19:20

22:18

assure 59:22

asterisk 7:15

asthma 48:20,23

49:1,5,17,18

50:18 52:13

54:12

asthmatic 53:3

ate 75:23

athletic 48:12

attached 12:11

attempt 27:17 31:7

50:9

attempted 32:11

attempting 17:18

attend 88:3,17

90:12 95:3

attends 88:7

attention 33:1

58:21,22 64:4

attention-deficit

74:3

attorney 41:13 99:3

attracted 34:25

attrition 11:23 13:7

26:3

auditor 18:23

August 9:5 63:22

Aurelia 2:20 26:17

115:9

Australia 76:11

author 38:15

authority 6:15 8:1

38:5 40:5 56:1

57:2

authorization 6:17

8:23 9:1,3 112:3

authorizations 1:5

4:12,18 8:18 9:6

10:3 11:9 15:13

16:8 32:3

authorize 8:11

110:13

authorized 4:24

7:18,20 33:18

101:19 102:21

103:3,6,10,11,15

106:11 111:17

available 5:3,24

35:2 104:18

108:4 112:20
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avoid 90:13

avoiding 28:15

awards 21:13

aware 27:1 39:9

47:19 72:10

104:25

awareness 108:7

away 31:8 68:15

awhile 62:2,9

B

B.A 60:19

B.S 60:20

backfilled 82:9

background 5:16

6:3,8 48:12 60:17

83:10

bad 73:19 78:14

81:22

bailed 84:19

ball 93:22

Ballinking 107:21

ban 23:8 32:20

112:13

banged 81:15

banned 34:2 89:15

bans 8:4

bar 21:1

Barr 3:15 96:11,14

115:18

Baruch 2:24 38:14

baseball 48:14

based 25:22 32:13

35:22 43:12

102:14 106:11

107:1

basis 21:11 25:23

28:23 29:2 39:21

42:18 55:8 78:15

84:14

basketball 48:14,16

Bay 46:20

beautiful 50:25

became 41:19

52:17 53:9 56:15

63:19,21 99:19

become 15:5 35:10

103:23

bed 73:19

begin 27:9

beginning 5:16

behalf 18:15 19:13

26:12,17 87:13

91:15 96:15

107:18,23

behave 53:11

behaving 53:3

behind 33:10 56:18

80:1 109:3

beings 102:24

belatedly 45:18

believe 11:12 21:20

23:24 25:10 37:6

38:19 68:22 70:4

74:25 78:23

85:4,22 92:18,20

93:17 102:6

104:2 110:13

believes 20:24 25:8

36:21

benefit 24:25 28:14

beside 73:25

best 13:4 29:6 35:2

96:24 109:7

better 30:25 31:14

36:8 37:14 50:13

66:20 70:17

beyond 12:8 31:5

56:12 59:2

biggest 67:11 85:21

bike 48:18

biking 52:19

bill 34:25 97:21

billion 7:3 16:9,13

22:24

billions 14:3 17:11

58:3

biology 60:20 85:24

BIPHENYLS 1:3

bit 6:13 41:24

73:16,24 79:20

83:20 87:10

black 78:22

blew 82:17

blood 28:22 86:4

95:13,14,16,22

114:9

bloods 68:7

blown 72:21

bluntly 42:5

board 13:15 96:15

Bob 72:4,24 91:22

bodies 28:25 33:6

91:2

body 33:12 44:4

45:8 68:10 98:19

books 59:6 74:24

boot 75:21

booties 83:7

borderline 40:10

bored 68:23

born 68:9

borough 2:20

26:18,21 27:2,23

46:18

boroughs 35:1

41:18

Boston 71:23,24

74:25 77:5 81:13

85:20

bottle 79:13

bottom 9:4 12:24

bought 55:24

box 55:24

boy 18:20 48:13

brain 75:20,22

Branch 2:7,11

4:4,9

brand 55:24

brand-new 52:22

break 5:19 50:15

53:22 71:6

breaks 50:14

breathe

49:12,19,21

50:21 54:3,8

78:11

breathing 50:10

51:5 55:19

bricklayers 71:13

Bridge 47:2

brief 41:12,20 87:6

briefly 91:20

bring 70:23 99:15

108:18

broad 19:14

broadly 33:15

BROADWAY 1:12

broke 79:20

Bronx 2:20

26:17,22 88:4

94:15

96:12,16,20

97:18

bronze 73:14 77:19

78:3

brought 55:23

80:19 82:22,23
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brown 90:9

bubble 54:12

buck 66:23

budgets 58:3

buffer 92:20

bugs 80:4

building 40:4 47:10

50:12 51:17

71:14,20 72:2,19

75:11,24

77:5,6,8,9 79:7

80:10,17 81:2,12

82:10,13,14,24

85:23,24 86:22

87:2 92:24 94:20

96:24 97:15

102:9 104:12,22

105:17

106:5,11,21

107:2,4,10

109:8,21 110:8

112:12

buildings 27:5

28:4,5 29:3 30:24

31:5 32:19

35:19,21 70:20

78:13 79:5

81:3,6,7 82:15

85:19 87:3 93:3

94:13,25 104:13

built 46:24 47:2

92:3 96:20 109:9

bulk 7:11

burden 8:25 9:2

28:12 32:6 44:4

101:24

burdens 28:3 58:3

68:10

burdensome

20:17,20 22:6

bureau 99:6,20

burn

78:9,10,14,21,22

burning 7:22

burns 78:8,9

Bush 36:12,15

bushings 24:10

business 2:25 38:15

75:22 87:19

108:24 109:1

110:10 111:7,8

businesses 113:8

C

calculation 44:13

California 30:2

38:16

campaign 79:1

Canada 16:14

17:20

Canadian 17:13,21

18:1

Canadian-like 17:8

Canadians 17:18

Canal 62:15,25

63:2,6 64:2

99:2,7

canaries 106:1

canary 54:9

cancer 8:1 65:16

capacitor 42:16,25

capacitors 9:14,25

22:12 25:6 42:8

70:1,15

capacity 38:23

Capital 1:14

capricious 8:25

carbonless 6:25

7:19

carcinogen 7:25

72:9 90:23

cardiovascular

32:22

care 77:15 97:10

career 18:22

caring 87:20

carpet 68:2

carried 63:15

carry 76:23

cartridge 24:14

case 13:18 22:13

23:16 24:10,11

42:3

cases 23:23 87:21

108:14

Casey 3:7 41:4

60:10,11 115:14

Cassandra 107:21

108:13

categories 12:17

category 97:4

Catholic 81:11

caulk 28:7 29:3

32:5,10,18 33:24

36:4,23 38:4

39:1,4 41:2,20,23

42:22,23 44:16

45:16 47:4,5

59:19 61:23 62:3

68:20 70:9 79:3

87:16 88:11

89:3,10,19,25

90:13,14 91:10

96:25

101:7,13,23

102:17

103:1,7,11,14,17

111:15,16 112:10

caulked 79:2 80:14

caulking 28:1

35:15,21 38:9

40:2 57:14

58:9,16 71:18,21

73:3 75:11,19

76:5

77:4,13,16,21

78:4,7,8,9,18

79:17,18,20

80:2,3,5,8,10,16

81:13 82:3 83:11

84:5 85:1

92:6,7,8,15,24

93:2 94:6,22 97:1

103:2

caulkings 75:12,16

caulks 7:14 69:8

70:2 100:24

101:16,18 103:25

104:6,9

106:10,15,19,24,

25

cause 25:23 32:21

33:8 55:3 75:20

86:14

caused 79:23 81:1

87:1

causes 80:25

causing 54:5

caution 18:11

cavity 80:1

CDC 29:11

95:12,16

CE 103:12

ceding 41:4

ceiling 70:2 80:1

ceilings 58:10

celebrating 46:23

center 56:17 72:5,6

CEO 99:10

certain 8:15 12:17

15:24 17:10 22:9

27:9 74:5,14

75:25 111:5

certainly 53:13

56:4 57:9 58:13

63:19 80:15

98:10 109:21

certainty 16:19
Capital Reporting Company

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CERTIFICATE

114:1

certify 114:7

CFR 102:18

chair 3:15 19:2

74:20 96:11

Chairman/CFO

3:24

chairs 74:23

challenges 14:18,25

15:20 22:25

23:18 91:3

chance 79:23

113:12

chancellor 99:19

change 23:9 28:23

32:4 33:11 36:18

39:12 46:17

83:25 85:19 90:2

91:12

changed 50:16

52:14 54:24

101:21

changes 35:20

90:14 102:1

channel 85:12,15

chapter 108:20

characteristics 9:13

charge 85:13 99:25

Charles 3:24

115:21

chases 80:11

check 58:16

chemical 2:12 4:9

8:2 32:20 95:2

chemicals 2:12 4:7

67:13 89:16 91:1

95:6

Chemist 3:7

chemistry 63:11

65:6 67:12

chief 2:6 4:3 99:20

child 29:7 46:19

48:12,19 49:8

51:4 52:1 53:1,6

54:9 55:3,19

59:13,15 63:17

childbearing 51:21

69:11

children 26:25

28:17,22,25

29:13 30:23

31:1,9 32:24 33:5

35:3 38:24

39:20,24 40:11

43:25 44:2,15

46:12 47:21,23

48:22 49:18

51:16,17 55:19

61:6 62:16 65:13

67:18 69:10

70:25 74:3 87:20

88:16 89:12

90:12 91:2,5,12

95:1,5,22 109:16

113:1

children's 39:11

45:20 90:21

child's 53:24 54:24

56:4

chlor 64:23

66:14,18

chloracne 7:23

73:6,19

chlors 66:20 68:24

choke 78:12

chord 73:3

chose 99:23

Christmas 53:22

chronic 7:23 90:18

Chuck 108:23

chunk 57:13

Circuit 9:4

citation 9:3

cited 102:4

cities 30:4,20

citizen 3:13 87:18

91:18

citizens 88:10

city 3:11

27:5,11,12,13

28:7 33:23 38:5

40:5,13,19 41:18

45:9 48:22

56:7,22 57:17

69:2 79:4 86:19

87:14

88:4,11,19,21,24

91:8,15 97:2

98:21 99:19,24

101:11,14

City's 35:3

citywide 27:12

34:19

civil 41:15

claim 43:4

clarifying 5:3

class 41:5 47:19

67:12 74:22

classes 62:24

classroom 42:21,23

43:1 53:8 54:1

55:12,18,21,25

56:4,25 58:5 59:4

66:4

classrooms 51:16

clean 40:5 50:25

51:13 54:2 55:12

56:17 64:19

93:2,3 99:8,13,14

110:18

cleaned 52:7

58:23,25 59:17

109:7

cleaning 51:15

55:7,18 59:8

cleanup 92:20

99:5,22

clean-up 34:13,16

36:6

clean-up's 63:7

clear 11:3 42:6

50:5,10 53:1

clearly 37:13 42:21

50:10

Cleveland 21:18

Clinton 31:24

clock 70:6 80:1

clogged 90:8

close 44:23 83:14

96:23

closed 81:19

closely 19:6 100:21

closets 80:12

closing 18:7 81:9

clothes 79:9

clothing 73:16

105:3

co 38:1,13 79:4

coal 21:16 54:10

coalition 3:11 86:20

87:13,14,17,24

88:3,9 90:4,11

91:9,16

coast 4:15 69:5

coatings 7:14 70:3

110:24

co-authored 60:24

Code 43:6

cognitive 32:22

33:4

cohesive 79:19,20

coincided 56:7
Capital Reporting Company

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coincidence 55:5

cold 48:24 49:1

53:21

Collaborative

47:20

collateral 16:23

colleague 87:9

College 38:14 60:18

College/City 2:24

colleges 81:7

color 73:10,13,15

77:24

colors 110:24

combined 21:15

comes 73:8 75:4

coming 6:1 36:19

51:13 53:16

61:13 62:19

69:16,22 74:20

83:21

commend 61:10

comment 10:5,12

19:18 20:11 28:9

30:12 77:2

100:20 113:13,14

comments 4:11

5:1,4,5,7,8,14,23

6:12 9:8 10:6

30:1 43:3 100:16

101:15 107:13

commerce 4:13

8:5,12 43:10

commercially 6:25

commission 114:16

commitments 12:3

committee 3:15,18

19:2,6,13 96:11

100:9,12

common 14:21 15:2

45:22 109:11

112:17

communities 90:23

community 37:9

45:18 71:2 87:7

90:6 106:2

companies 12:16

13:13

14:10,14,18

16:17 19:5 20:18

company 1:15

12:12 14:23,24

17:2 18:24

19:8,13 66:2

82:20,22 83:2

99:8

complaining 49:11

complaints 51:1

complete 62:6

completed 34:24

38:4 90:16

completely 42:23

82:25 108:22

complex 19:25

compliance 2:8 4:4

13:22 17:22

18:25

complicated 29:5

67:12

complicates 15:2

complications

32:23

comply 13:8

complying 16:16

component 67:16

compound 76:10

compounds 6:23

comprehension

59:2 74:6

comprehensive

27:6 106:20

compromise 12:3

24:10

compromised 26:6

compromising

21:25

concentration 34:6

36:5 39:1

102:20,25 104:6

106:16,24

concentrations

28:19 39:18

43:10 101:18

103:21

concerned 29:16

35:11,13

87:14,18 88:9,15

89:6 102:3 108:3

112:16

concerns 23:18

24:7 29:18 33:9

35:22 36:16

53:23

concludes 113:10

conclusion 106:9

conclusive 108:15

condition 54:23

111:2

conditioner 57:10

conditioning 52:22

56:3 79:24,25

conditions 53:9

111:5,22

conduct 88:21

105:7

conducted 37:5

conducting 28:6

conductivity 7:8

Conference 1:13

confidence 45:3

confident 66:13

configuration

14:13

congener 66:16

congeners 6:24

66:17

Connecticut 108:24

109:6

consequence 33:14

Conservation 99:13

consider 17:17

40:17 89:1,8,24

91:4 105:14

106:17

consideration

31:16 44:14

104:9

considerations

27:21 32:14

considered 16:18

104:3,7 106:16

considering 4:14

10:3 15:10 42:19

90:5 91:3 108:9

constant 11:21

constantly 49:14

constitute 33:3

constraint 8:9

constructed 32:19

34:1,21 112:13

construction 37:2

38:5 40:5 47:5,7

48:8 50:11

51:8,14

54:5,21,25

56:1,21 57:1

58:1,8,24 60:1

86:22

constructionrelated 31:3

consulting 53:24

consumers 14:4

16:6

contact 69:1,11,23

77:3

contacted 92:13
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94:17

contain 22:5 101:7

contained 14:20

25:4,6 42:16

53:14 55:14

90:19 113:7

container 72:12

containers 73:8

containing 11:16

12:8,10 13:3,16

15:3,5,8,18

16:2,15,20 17:3

18:8 23:7 33:24

38:8,9 40:2 89:20

90:12 100:24

101:16 103:7,18

111:19

contains 23:11,20

24:1 103:14

contaminants

39:20 54:15 81:5

101:13 105:22

contaminate 59:5

contaminated

12:21 22:13 28:6

29:1,3 30:13,24

40:8 79:6,7 87:16

89:10,25 90:8,13

91:25 92:5,23,25

93:12 96:9

103:23

contamination

26:25 27:4 28:13

29:7,8,12,13,18

30:8,18 31:4

33:22 35:18

36:4,7 38:21 46:7

101:8

contemplated

11:11 13:20

content 18:5 22:20

contention 94:23

98:7

continue 31:8 35:4

42:15 48:16

102:1 111:2

continued 3:1

8:7,12,17 18:9

24:5 54:18 91:13

103:16 110:14

111:14,17,22

112:19

continues 15:4 32:7

35:24

continuing 12:25

18:13

continuous 73:13

contractors 92:9

100:23 104:11

105:6 107:10

contradiction

42:11 45:1

contradictions

44:19,25 45:1

contrasting 110:24

contributing 26:4

control 6:16 27:8

34:3 49:1 58:11

72:10 74:11,14

103:5 111:24

controlled 48:23

controller 93:17

controls 107:5

convenience 27:21

convenient 60:8

convention 96:3

conversation 9:22

Co-op 88:4

Cooperative 14:16

cooperatives 14:17

coparts 86:2

copies 100:18

co-president 38:3

copy 7:1,19

corner 75:25

correctly 22:17

65:4,5 111:7

correlation 25:20

cost 9:18,19 10:1

11:19 13:10 15:9

16:4,8,15,18,21,2

2 17:9,10 18:14

20:23 22:23

23:17 25:11

28:15 44:8 69:17

91:4 110:8

cost-based 36:11

Costco 55:24

cost-effective 11:19

costing 82:11

costs 10:1 14:4

16:10,23 21:23

24:3 36:6 44:14

Cotar 91:15

coughing 52:2

Council 56:8

count 86:13 100:5

counted 71:19

counter 50:9

countries 17:17

country 12:15

29:19 76:10

county 40:15 92:12

114:4

couple 77:15

107:23 111:12

coupled 11:21 13:7

course 16:5 18:22

44:14 72:9 73:23

84:25 97:19

107:25 109:19

110:5

covering 59:7

crack 80:2

craft 2:6 4:2 27:17

115:5

crap 79:9

crawled 56:8

create 29:12

created 17:4 30:5

93:24

creating 28:24

30:22 51:3

crew 77:4,5 83:14

crews 51:14

crime 86:3

criminal 99:18

crisis 33:22 45:23

criteria 37:11

105:15

critical 14:8 19:17

20:7

cross 95:20

crossed 50:17

crucial 28:20

crust 67:16

CTT 47:19

cubic 67:7

curious 92:2

current 4:12 9:6

32:3,9 36:20 37:3

60:14 89:9,17,24

90:14,25 91:9,11

98:9

currently 7:2 8:23

18:24 19:3 20:11

37:3 39:22,25

40:21 101:18

102:6 111:13

curriculum 108:10

custodians 50:25

51:12

customers 12:4

22:1 24:6 108:14
Capital Reporting Company

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cut 58:9 78:2 84:5

cutting 7:13 55:1

75:10 76:18

D

Daddy 79:11

DAEMIAN 2:2

daily 34:5 39:21

51:7 54:20 78:15

90:17

94:14,17,18

107:25

damage 32:23 33:8

75:21,22 109:25

Dan 2:6 4:2 6:5

10:5 115:5

dangerous 39:19

42:25 43:1,2 59:5

dangers 26:25

32:15 39:15

Daniel 3:13 91:18

115:17

data 5:1 6:11 17:9

20:3 25:22 45:15

database 28:24

29:12 30:23 95:9

DATE 1:9

daughter 97:18

108:25

daughters 88:3,7

David 100:16

Davis 2:17,22

18:16,17,18

31:19,21,22

38:17 115:8,10

day 49:10,13,25

50:3,8,20 51:17

52:18 54:6 66:21

69:1 78:16,17

84:20 114:12

daylong 55:20

days 11:6 29:24

49:10 64:21,22

109:11

day-to-day 19:12

de 17:4 24:21

dead 63:23

deadline 13:4,17

42:2

deadlines 17:19

deaf 81:8

deal 29:23 95:14

107:25

dealing 31:11 99:6

108:13

decade 34:2

decades 15:16

19:10 23:2 31:6

43:20

December 111:17

decided 6:11 53:22

decision 9:4 90:1

declining 23:12

25:1

decreased 15:17

decreasing 12:11

dedicated 19:11

deems 40:8

deep 71:19

deeply 36:1 88:15

deferred 112:2

deficiencies 44:1

108:15

deficit 33:1

defined 103:20

defines 101:20

definitely 23:20

67:19

degraded

110:20,22

degree 42:10 45:2

50:2 58:25

degrees 80:25

delay 47:24

deliberate 104:1

deliver 5:12

demand 14:5

demonstrated

110:15

department

34:8,12 35:7

45:10 62:14

63:12 88:12,19

92:13,16,22

93:1,19,20

95:12,18 98:21

99:12,19,21

101:11

depth 14:12

Deputy 2:20 26:17

dermal 65:23

describe 54:9

describing 27:3

desks 59:6 74:23

destroy 24:9 111:7

destroying 113:8

destructive 26:9

detail 42:10

details 110:4

detect 56:16

detected 33:24

56:24 100:6

detection 57:20

61:1 66:9

detections 61:3

deteriorating 85:19

deterioration

111:23

determination 8:15

15:15 95:24

determine 9:6 18:4

22:20 27:16

106:24

determined 11:25

25:15 54:17

determining 11:2

23:20 29:4

detrimental 74:10

91:1

develop 17:9

developed 10:21

61:2 106:5

110:17

developing 32:24

33:6 62:1 91:2

development 33:4

42:7 45:2 60:22

developmental 7:24

diagnosed 48:21

Diaz 26:21 27:2

dielectric 6:25

7:10,12 15:22

23:23 24:16

dies 67:5

dietary 44:3

difference 75:8

differences 14:9

different 6:23 7:8

34:4 58:21 71:11

90:7 108:1,22

differently 14:24

difficult 17:7 20:23

23:3 40:23 48:6

62:5

difficulties 17:18

difficulty 15:7

111:20

diligently 19:12

dilution 35:21

DiNapoli 93:16
Capital Reporting Company

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dioxin 80:25 81:1

direct 55:3

direction 57:18

directly 24:4 55:17

director 2:15 4:6

10:13,15 100:11

dirt 82:9

dirty 55:8

disability 74:5

disappointed 87:21

disappointing

36:19

discovery 27:4

103:8

discredit 42:5

discrediting 44:19

46:2

discreet 21:22

discussion 97:22

disease 63:24 73:22

disorder 33:2 74:4

disposal 7:4 9:25

24:3 34:14

disposed 12:22

25:2,5 67:17

72:13

disrupt 90:20

110:10

disruptions 14:7

16:24

disservice 45:5

distinguish 43:16

distinguished 26:19

88:6

distribution 4:13

8:4,12 10:19

12:21 14:10

15:24 19:5 22:16

24:12,13 25:3

43:9

district 34:1 69:3

disturb 101:6

disturbance 43:25

104:16,22 107:12

disturbed 36:1

102:1

Division 2:7,12

4:4,7

dizzy 49:23 50:6

52:3

Doa 4:6

docket 5:9,24 10:6

doctor 55:11

documentation

107:22 108:4

documented 6:18

32:15 43:13

documenting 90:17

documents 112:10

DOE 98:5 100:2

dollars 14:3 17:12

93:4

done 26:6 56:11

57:23,24 60:20

65:8 66:25 67:1

75:7 89:5

98:11,12 108:7

Donegan 3:5 46:10

115:13

door 27:25 57:14

70:8 98:13

dose 79:8

dosing 67:5,6

dot 78:20

double 79:8

doubt 68:5

downstairs 84:7

downtown 81:13

downward 41:2

dozens 56:9

Dr 91:22

dramatically 15:9

23:6

drastically 15:19

54:24

dressed 83:6

dries 84:2

drink 99:15

driven 102:2

driving 33:10

dropped 72:16

Drozdov 3:21

107:14,17 115:20

drugs 50:7

due 23:8 25:21

63:24 69:11

dump 62:17 73:9

dumped 99:8

dumpster 81:11,15

duplicate 53:20

during 18:22 36:15

51:7 65:2

75:1,4,7 81:21

87:19,22 95:19

96:20 97:2,19

99:21 112:23

dust 51:14 52:9,16

54:2,4 55:18

56:20,21 58:11

59:5

72:8,12,18,20

74:11,14 75:3,6

76:19 83:21 84:3

dust-free 54:13

dwindled 23:8

dwindling 11:22

E

earlier 12:13 15:13

22:11 87:10 88:5

99:2

early 21:19,21

51:13

ears 81:8

earth's 67:16

easily 19:21

East 69:5

Easter 50:15

easy 44:24 80:5

echo 43:2 88:25

ecology 65:1

economic 11:23

25:17 32:13 33:9

35:22 43:5 44:8

90:4 91:3

102:3,5,14

106:12

economics 70:21,23

ecosystem 37:18

ed 47:21,22,23,25

48:2

edge 76:6

education 34:8,12

35:7 45:10

88:13,20 93:20

95:18 98:22

99:20

effect 14:5 63:23

110:4

effective 105:24

effectively 20:5

effects 6:15

7:21,22,24 37:14

61:1 65:18 67:4,7

90:18

efficiency 104:14

efficient 11:2

effort 11:15

12:7,9,25 15:3

23:25 24:2 26:15

27:16 37:13
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40:4,6,20,22

88:13 111:21

efforts 12:1,12,14

13:12 15:19

21:20 23:9 26:3

37:8

eight 34:4 46:21

60:24 107:7

eight-year-old 61:7

either 12:22 72:2

79:21 93:14

elasticity 7:7

elected 34:17

electric 2:18

10:17,22 14:4,11

16:6 17:10,21,24

18:19 19:8 20:14

22:1 26:12 75:14

99:7,11

electrical 7:7,12

10:17 14:6,16

15:14,18,22

16:15 22:3,15,18

23:1,5 25:21 66:2

electricity 10:19

electronically

100:18

element 28:20

46:11,14

elementary 33:25

92:2 97:16

eliminate 13:2

33:18 90:24 96:8

eliminated 44:6

eliminating 42:19

45:25 89:9,24

91:6 96:4 102:7

105:21

Elizabeth 1:14

114:5,15

else 54:2 58:10 60:9

93:9 113:14

embarrassment

42:5

emergency 34:15

63:22 75:2

emerging 33:22

45:23

emitters 94:23

emphasize 13:11

employ 13:8

employed 35:12

36:12

employees 14:17

24:23 28:17,22

29:1 30:23

employer 60:14,15

employers 105:5

empty 78:19

enable 75:16

enactment 103:4

encapsulate 110:22

encapsulated 82:13

encapsulation

111:24

enclosed 8:13,15

42:17

102:9,21,23

103:9 106:10

encourage 5:14

44:21

endocrine 32:22

endpoint

65:16,17,18,20

energized

24:8,12,13,21

energy 104:14

enforce 44:8,10

91:11

enforced 10:21

64:11

enforcement 2:7

4:4 68:12

enforcing 44:12

engage 16:3 18:3

engaged 10:20

104:21

engaging 13:13

engineering 107:5

England 76:11

enormous 25:11

111:20

ensure 12:20 13:21

16:1 21:24 37:17

102:24 111:1,25

entered 88:20

entering 27:10

entire 88:23

entirely 32:13

environment 4:21

7:6 9:8 15:16

21:14 43:20

48:21 51:4 59:13

64:12 69:23

102:25 104:20

105:1,23 110:17

environmental

2:10,17 4:8 17:20

18:18 24:25

36:3,13,17 37:16

38:14,17 39:7

41:15,17 43:13

44:3,4 52:13

63:11 65:1 85:13

87:8 95:14

99:5,6,13 100:21

101:11 102:2,4,7

105:25

environmentallyrelevant 67:4

EPA 1:12 2:8,13

4:5,15 5:2,6,12

8:11,14,24 10:20

11:3 12:5,13 16:7

17:10 19:6,11

20:8,24 21:13,21

22:17,25 23:15

25:15 27:5,19,20

28:14 29:10,14

30:1,10 32:11

33:15 34:2

35:7,19 36:8,21

37:13,15 38:25

39:3,14

40:8,10,21,25

42:18 43:7 44:19

45:8,13,17

57:18,22 61:10

62:1 63:12 88:20

89:8,13,21,24

90:4,24 91:9 93:1

95:7,11,13,18

96:6 98:5,21

99:12,21 100:4

101:17,22

102:13,17

103:1,3,8,12

104:5,9

105:14,18

106:9,14,17,19

108:9 109:7,19

110:13

111:12,18,22

112:2,3,9,15,19

EPA-HQOPPT-2009 5:9

EPA's 4:9,12 12:1

18:8 32:1 36:20

39:25 89:16

100:20 105:13

106:4

equal 25:4,7

equally 45:12

equipment 7:12

9:13,15,18

11:16,18,22

12:2,8,11

13:3,5,17,24

14:1,6,11

15:4,5,8,14,18,22

16:1,2,9,15,20

17:1,2,4,6,19
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20:14,19,22,25

21:6,8,9,11,22

22:4,10,19,21

23:1,5,10,14,20,2

2,24

24:1,8,9,16,17,23

25:1,9,13,14,17,2

1,23,25 26:2,5,11

70:16 105:10

107:7

equipment's 12:19

era 47:2

error 57:4

especially 36:19

48:22 65:19,24

75:5 89:7,12

essential 105:14

establish 9:2 29:12

established 17:20

42:21

establishment

106:25

estimated

16:8,15,20,22

22:23 93:4

estimates 16:23

etcetera 75:6

evaluate 112:6

evaluates 105:16

event 42:20

events 9:23

eventual 36:25

everybody 62:4,15

65:7 85:6 107:17

everybody's 70:7

everyone 20:8

44:21 60:10

61:13,19 66:13

78:24 82:18

everything 52:7

68:21 82:9 83:1

everywhere 59:14

93:9

evidence 33:12

102:16 106:13

108:15 111:23

exacerbated 50:19

exacerbation 50:2

exact 18:2

exactly 74:18

examine 23:21

examining 37:1

example 9:21 14:15

examples 42:13

103:22

except 15:25

exception 8:6

exceptions 8:5,7

excessive 109:21

excited 46:22

exciting 46:22

excluded 103:19,22

104:3,4

excluding

101:20,21 103:18

exclusion 32:6

excuse 103:13

106:8

execution 21:24

executive 2:15

10:13,15 96:15

108:25

exercise 35:23

exist 98:13,14

existed 7:17

existing 20:20

33:17 40:23

97:14 112:7

exists 59:14 70:25

expanded 23:6

expected 31:12

expenditure 14:3

expense 111:20

expenses 10:17

expensive 22:7 23:3

44:10,12 80:15

experience 34:17

105:5

experts 56:12 57:8

expiratory 53:2

expires 114:16

explain 11:12 23:4

65:9 73:6

explained 57:4

83:21 87:10

explicitly 113:1

explosion 47:1

expose 31:9

exposed 32:24 35:5

54:14 65:13 66:5

68:10 90:7 95:6

100:24 105:21

106:1 108:16

110:20

exposure 29:5

32:16,25 33:12

43:14,24 44:4,16

45:16,19 47:12

65:23 89:23

90:18 91:13 98:3

101:8 102:24

103:7 104:8

105:8,11,15,20

106:17 111:25

112:6,16,18,23

exposures 104:10

105:25

expressing 60:13

extend 19:18

extended 39:21

extends 31:4

extension 20:11

extensive 34:9 38:3

40:4,6 42:1

extensively 38:19

39:10

extent 7:16

exterior 55:15

110:21

External 3:15 96:11

extra 51:13

extraction 61:2

extractions 60:22

extraordinary

111:21

extreme 48:25

extremely 43:24

eyes 7:22

F

fabulous 64:12

face 7:22 14:18

46:6 97:24

faced 15:1 17:18

faces 15:1 53:7

facilities 22:2

29:1,9 112:13

113:2

fact 8:21 13:13

21:12 22:5 28:5

43:2 52:14 69:6

70:22 88:4,16

89:13 98:5

facto 17:5

factors 102:3,5,15

106:12

faculty 35:4 66:6

fail 70:24,25

failure 9:18 24:18

25:21,25
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fair 69:18

fall 32:18 52:21

59:20 63:23 75:5

81:14 112:9

families 63:2

109:14

family 63:25

famous 71:23

fantastic 50:24

52:18,23

feasible 22:20

February 114:16

federal 5:4,13 9:10

27:19 30:22

31:13 36:10 43:7

77:8 104:14

feel 46:11,14

49:19,21 69:18

80:23 85:8 98:20

feels 50:5

feet 70:10 71:21

73:12 80:16

94:21 98:24

100:4

fell 81:8 110:19

fellow 74:12

84:7,18

felt 56:2 66:13

74:12 81:22 85:8

fence 77:17

fewer 14:17

Fibers 2:11 4:8

field 12:22 63:5

fields 90:9,17

fifth 4:14 9:4

Fifty 64:10

fight 48:7

figure 51:25 52:15

54:16 69:21

92:25

figured 75:22

93:7,13

filled 12:23 15:22

filter

55:7,10,13,15,16,

22 56:3,6 57:10

filtering 55:18 56:5

filters 56:18

final 17:12 39:4

44:17 95:24

112:2

finally 29:14 50:17

52:3

financial 28:3,12

financially 40:23

finding 9:1 43:12

61:4 67:7

findings 58:20

finds 43:6 80:2

fine 50:15 51:25

85:11,14 109:18

finger 72:15

finished 72:16

Finland 73:2 76:9

fire 9:22 98:24

100:5

fired 21:16

firefighters 78:12

firesafing 80:14

firm 41:16

first 4:10 7:9

10:12,25 11:12

27:23 35:9

38:19,20 47:12

48:3 50:20 61:9

62:13 70:21

73:22 79:1 81:4

82:8 86:5 103:1

fish 59:11 68:4

fitted 74:15

five 35:1,17 36:25

41:18 53:7

82:15,16 95:19

98:6 107:3

five-school 35:8

fixtures 68:20

98:14

flat 42:11

flexible 47:9

floating 86:1

floor 1:13 47:11

70:10 72:17

80:11,13

82:21,23 97:17

floors 71:20 97:17

fluid 7:10 15:22

24:12,17 26:10

fluids 6:25 7:11

fluorescent 68:20

98:14

fly 66:22

focus 65:11,21

105:7,18

focusing 64:2

folks 9:9 61:13 65:7

food 32:17 68:4

70:24

foot 82:11

football 48:14,15

53:21

force 33:10 67:21

forced 56:15

forefront 53:16

foreman 83:12

84:17,21

forget 63:13 67:9

74:18

Forgive 100:14

forgot 92:11

forgotten 63:21

form 28:22

formally 11:1

former 38:1,12

formulate 27:6,12

formulating 10:8

28:8

forth 109:12

forthcoming 38:15

forward 7:18 45:12

60:9

foundation 63:13

fourth 108:23

fractured 80:3

frame 30:7

frames 98:13

framework 89:17

frankly 44:9

free 3:11 50:9 56:23

86:20

friends 77:9

frightened 90:24

front 57:14 99:16

frustration 63:16

full 58:5

full-time 20:4

fully 14:1 104:25

fun 9:24

function 14:13 44:1

functional 14:1

functioning 24:15

functions 80:21

future 33:8 37:17

80:7 91:4

futures 91:14
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G

gain 32:16

gains 13:5

gas 10:22 19:8

80:25 81:1

gases 73:17

gather 4:11 20:9

45:15

gathering 11:2

Gazon 3:11

86:19,24 87:4,5,7

115:16

GE 64:19 99:18,22

gender 43:24

general 34:7

47:22,25 48:2

99:7,10 104:23

generally 8:4

general's 99:3

generating 10:17

generation 10:18

19:4 62:25

68:8,10 108:24

generator 14:10

gentlemen 71:12

George 3:9 71:12

84:17 88:5 91:24

93:10 94:12,14

101:1 115:15

Germany 76:11

gets 63:15 83:17

getting 47:18 48:9

49:12 51:15 61:8

65:5 93:21,22

Gibbs 63:19

Gigi 3:11 86:19

87:7 115:16

given 11:20 13:1

18:12 19:14

29:20 47:1 60:25

90:2 104:9

105:10 111:20

gives 75:15 101:22

giving 109:20

glass 82:20,22

83:19,20 99:15

globally 96:2

goal 12:1 18:8

goggles 83:8

gone 58:24

68:12,15 83:1

gory 110:4

gotten 58:21 82:19

86:6

government 8:18

27:2 89:21

governmental

95:15

grab 71:22

grabbed 92:19

Grade 46:20,22

49:3 56:25

graduate 60:18

grandchildren

71:16 74:4

grasp 46:16

great 7:6,16 11:14

47:6,9 50:16

60:12 62:11 63:3

67:23 86:18

95:18 110:11

111:20

greater 25:4,7 33:7

38:8,10 40:2

43:11 69:9 89:17

101:18 103:15

greatest 68:10

105:19

greatly 24:18 26:8

38:7 43:17

green 101:3

Greene 2:20

26:17,19 115:9

grinding 55:1

grossly 29:6

ground 77:17 81:14

92:10 110:19

group 6:23 10:16

40:12 60:16

growing 29:18

34:18

grown 23:6

guarantee 19:19

guess 10:9 57:23

62:8 86:15

113:15

guessing 77:24

guidance 19:1

39:16 106:20,21

108:11 112:24

guidance's 45:13

guidelines 93:23

guides 106:22

gun 24:14

gutted 82:25 86:23

guy 76:22

guys 9:24 76:17

82:24 86:7,13

H

habitable 101:9

half 7:5 25:4

47:21,25 71:18

76:20 78:2

105:12

hall 3:24 5:20

hamper 11:19

hand 5:11 114:11

handled 111:7

handout 5:10

hands 75:23

happen 62:6,7

80:18

happened 54:19

71:9 93:8 109:5

happens 64:3 79:14

84:3

happy 57:24 61:24

82:18

hard 11:18 61:11

62:5,9,10,21

63:14 65:7,9

70:14 74:8 75:2

76:2 78:18

100:18

hard-and-fast

13:17

harder 15:5

harm 46:5

harmful 33:13

90:17

harms 41:17

Harvard 72:24

81:5 85:23 86:4

91:23

hastily-scheduled

34:15

hat 83:7

hats 37:25

haven't 58:18

having 9:24 52:4

77:22 84:11

86:10 99:20

havoc 11:23

haystack 15:6

16:12 25:11

hazard 101:12

105:8

hazardous 72:14

108:8

hazards 43:13
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105:1,9 108:1

headquarters 5:12

health 3:16,19 6:14

7:21 9:7 15:15

24:25 28:16

37:17

39:2,7,11,17,25

43:12,13,20

44:14 45:20,23

46:1 47:25 62:14

63:12 65:1,2 72:5

74:10 89:12,19

90:18 91:7,12

92:12,16,22

93:1,19 95:12

100:10,13,22

101:4 102:4

104:8 105:13,15

106:2,8 110:16

healthy 48:12,19

heap 55:16

hear 51:24 62:9,12

67:13 79:24

91:19

heard 19:3 23:3

47:6 53:14 77:1

87:16 97:22

hearing 30:2 36:2,9

63:16 97:5

hearings 29:17,20

30:3,6,7,20 56:7

heart 49:23

heat 7:7,10 9:14

53:8,12

heavily 110:17

heels 89:7

Heights 92:1

held 30:3

Hello 41:11

Hells 31:24

help 47:5 49:24

52:7 54:2 55:12

72:8 90:4

helpful 35:23

Helsinki 73:1 76:8

96:3

HEPA 72:12

hereby 114:7

hereunto 114:11

Herrick 72:4,24

Herrig's 91:22

he's 48:12,19

50:3,4,5

hey 77:11 84:2

Hi 87:5 100:11

high 40:9,10 69:15

81:11 87:25 88:8

96:12,16 109:23

112:11

higher 16:11,13

36:5

highest 30:20 34:6

104:10

highlights 59:25

highly 66:24

highways 90:8

history 62:11,22

91:21 95:21,22

hit 72:17 75:2

hits 85:21

hold 10:9 19:3

73:11 83:19

98:23

holding 87:6 100:4

home 18:20 50:13

52:4 55:10

79:8,11

homegrown 63:19

honest 62:8 64:14

hooked 72:11

hope 42:3 59:24

host 99:11

hot 18:21 47:14

85:1,17 94:17

hotels 81:23

hour 84:9

hourly 84:14

hours 48:15 50:21

52:18 53:21

87:19

house 39:20 54:13

86:3

housing 81:20

Hubbard 3:24

Hudson 64:19,20

99:9

huge 11:19 69:3

huh 71:11

human 7:25 9:7

15:15 29:5 39:2

43:13,19 68:7

89:12 102:24

105:24 112:22

humans 67:23 68:4

humid 18:21

hundred 66:12 93:4

hundreds 11:4

14:19 24:3

35:18,19

70:10,15 78:15

96:22

hurdle 15:2 50:18

hurdles 22:9

hurt 109:25

husband 53:22

hydraulics 7:10

hygiene 3:22 72:7

107:16,19

hygienist 83:10

100:17 108:19

hygienists 107:24

hyperactivity 33:2

I

iceberg 98:7

I'd 54:12,13

71:18,21 72:16

73:20 75:18 77:1

111:6

idea 51:9 65:11

74:7

identical 76:10

identification 13:15

17:3 20:13 23:19

26:7

identified 16:3

30:9,16

identify 16:19

19:21 20:18,21

21:11 22:5 25:18

27:6 66:14,19

identifying 11:17

15:7 21:5 22:25

ignore 68:2

II 45:8 61:19

ill 63:21

I'll 41:20,24 42:13

43:2 46:1 59:11

64:13 65:10

69:19 85:10

86:15 87:11

88:25 99:15

illegal 103:6

illustrate 64:3

illustrates 12:14

I'm 4:2,5 6:5,6 9:20

10:9,14 19:16

26:20 27:1 38:23

41:13 46:11,12

57:7 59:11,14,19

60:13,18 61:6

63:1 64:2 65:11

69:4 70:21

71:11,20,22
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79:12,14 80:6

83:7,14 84:20,25

85:8,16 86:21,22

87:6,7,12 91:19

95:7 96:14,19

98:18,19 99:1

100:13,14,15

107:17 109:20

110:3,11 111:4,9

imagine 48:14

51:19 52:20

immediately 34:9

112:21

immune 32:22

43:25 90:20

impact 9:22 46:16

91:1

impacts 10:2

impair 24:4

impediment 33:3

impetus 94:13

implemented 10:21

12:20 20:25 21:3

74:13

implementing

23:16

implication 16:18

28:9

importance 45:19

important 13:19

15:11 17:17

21:21 26:15,23

29:20 45:11

46:15 48:2 53:15

70:21

importantly 45:12

impossible 17:24

56:16

impracticability

15:10

impractical 18:3

impression 97:8

impressive 13:12

improperly 67:17

improve 52:5

112:18

improvements

64:15

in/day 66:21

inaccurate 29:6

56:2

inadequate 29:25

30:6 34:12 40:16

89:1 97:23,25

inadvertent 104:18

inaudible 86:23

87:1 92:1

95:13,17 104:19

107:20 110:7

Inc 2:2 3:7

incapable 51:4

inch 71:18,19

inches 57:20

incinerated 80:24

include 16:23

106:23

including 21:5

27:10 70:20

101:3 112:13

inclusion 46:4

104:1

incomprehensible

30:2

increase 24:18,19

26:8 28:11

104:14

increased 16:24

33:2 39:7 50:7

66:8 97:14

increases 15:9

increasing 44:22

increasingly 35:10

incredible 49:25

incremental 13:5

69:16

incur 25:10

Indeed 39:3,14

indicated 27:14

111:13,18 112:4

indication 100:2

individual 66:17

indoor 105:23

industrial 3:21 72:7

90:10 100:16

104:24

107:16,19,24

108:19 109:13

110:17 113:2

industry 13:10

17:11 36:16

53:10 68:22

70:14,19

inefficient 23:13

infected 78:24

inform 107:10

information 5:1

6:12,21 11:3

20:10 39:8

90:15,19 96:24

97:1 112:5

informed 7:16

96:17

ingestion 32:16

65:21

ingredients 103:25

inhalation 32:17

53:1 65:22

104:18

inhaled 49:15 50:8

inherent 65:25

initiating 4:17

initiative 20:7

initiatives 45:15,21

101:3

injury 43:12 89:19

111:3

inks 7:14

inoperable 47:14

in-place

106:15,21,23,25

input 101:17

inside 42:25 48:17

82:25 109:11,12

insomnia 68:23

inspect 13:23

inspection 15:25

107:3 110:25

inspections 8:8

instead 65:12 91:4

institutionalize

31:1

insufficient 37:7

104:9

insulation 111:24

insurance 9:18

intact 14:1 16:25

24:15 42:24

intake 95:22

integrity 14:1 24:11

26:5

intellectual 42:5

45:2

intellectually 44:13

intended 104:24

112:4

intent 6:7 33:20

intention 20:6

intentional 103:24

interacted 19:6

interest 3:3
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interested 44:22

114:10

interesting 97:7

interim 112:22

interior 55:15

57:14 110:21

internal 18:23

interpreted 13:14

interruptions 13:25

24:24

introduce 34:20

introduction 37:24

105:22

inventories

12:10,16 13:3

inventory 11:22

14:11 15:3 20:2

investigation 94:14

investigative 94:18

investigatory 34:5

invited 113:13

involved 10:18

35:16 41:19

57:19 60:16 72:4

93:1 101:2,5

109:19 113:4

involvement 33:21

involves 111:11

involving 38:4

irritation 7:22,23

Island 46:13,21

47:1 97:13

isn't 44:7 55:5

66:22,23,24 98:1

issue 4:11 26:24

28:6 29:17

30:8,16 34:18

38:18 39:9 59:20

65:5 66:7 83:11

85:18 87:25

88:14 89:4 90:3

91:21 93:15,20

94:4,10,19 100:3

102:17 112:4

issued 4:15

issues 19:17,25

20:6 29:23 99:5

100:22

item 102:20

items 15:18 22:5

23:5,22 108:17

111:23

it's 7:18,23 9:9

13:21 26:1 41:25

42:6,17,25 44:24

46:6,25 47:20

48:2,21 53:15

59:2,12 61:16

62:6,8,10 63:5

64:2,7,13,14

65:3,4,7,12,17

68:19,20,25

69:4,15 70:11,23

72:6 75:1,6,7

76:2,9,12,13,16,2

4 77:8,16,21

80:2,3,5,14,18

84:1,4

85:6,17,18,19

86:25 92:21

93:8,17 94:5,7,8

95:2,17 96:22,24

98:25

109:1,18,22

110:4 112:24

I've 47:6

60:20,24,25

71:13,23,24

72:3,25

73:4,21,22 74:2

84:10

J

Jack 99:11,25

Jackson 27:3 41:22

112:15

jail 85:11,14

jammed 47:14

January 34:23 35:6

jeopardize 13:25

Jim 2:15 10:12,14

19:3 23:4 115:7

job 10:7 50:16,22

53:15 54:5,25

55:2 66:1 70:22

77:14 81:19,21

82:19,20 84:22

97:23,25

98:11,12 105:7

jobs 53:18 74:14

81:9

Joe 99:18

John 63:21,23

joined 4:5

joining 4:19

joint 82:12

joints 71:18 76:1

Jonathan 2:22

31:19,21 115:10

Journal 38:17

Jr 26:22 27:3

July 5:8 34:24 42:2

jump 49:20,22

74:17

jumped 77:17

jumping 48:18

June 27:1,8 63:21

109:2

Justice 41:15 87:8

99:20

justification

28:2,11

justified 11:24

K

Kellogg 3:24

108:21,23 115:21

key 6:8 57:13 83:17

105:15

kick 93:5

kick-off 63:10

kid 52:20 54:8 79:2

kidney 63:24

kids 53:3,7 59:24

65:19,24 66:3

71:15 79:3,9 81:2

85:18 86:10,13

95:3

Kim 81:16

kindergarten 49:3

kinds 86:9

Kitchen 31:24

Klein 99:18

knees 73:6

knew 43:3

52:9,10,14 53:19

54:4,10,23 55:3

61:10 66:2 74:8

knocked 110:7

knocking 70:8

known 12:17 20:16

30:24 65:14

90:21,22 97:7

98:2,16

Kotar 88:2

L

lab 55:14 57:4

64:19 66:21

67:1,3 70:23

labeling 106:24

laboratory 63:11

64:14,21

labs 85:20

laced 99:15

lack 28:20 30:1
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35:15

lacking 94:5

ladder 86:8

laden 32:17

ladies 71:12

LaMar 3:18

100:9,11 115:19

landed 109:4

landmark 45:9

large 11:16 12:4,17

16:20 17:2,21

18:4 22:11,15

25:6 77:6,7 106:2

larger 25:18

largest 17:3 30:4

last 11:1 19:7 21:2

27:1,8 35:18 42:9

102:11 107:9

lasting 99:5

lastly 25:20

late 7:16 38:25 43:4

61:8 73:5

later 4:15 5:15

43:20 53:14

54:19 57:4 69:22

99:18

latest 39:22 40:7

lauded 35:9

Laughter 74:1

launching 45:15

law

38:14,15,17,20,2

1 41:16 94:7,9

laws 62:20 86:9

Lawyers 3:3

41:9,14 87:9

lay 65:9

lead 14:3,6 64:19

67:14,15,16

91:13

leader 12:6

leadership 36:20

99:23

leads 13:18

leaking 9:17

learn 63:9 66:4

90:21

learned 34:8 63:14

learning 33:4 47:24

74:4

least 16:5 30:3,20

35:5 45:12 51:19

89:4 93:6

leave 84:19 110:11

led 29:13 34:15,19

Lefkowitz 3:13

91:18,19 115:17

legislation 34:20

35:25

legislators 94:2

legs 73:16,18 79:9

less 8:25 9:1 23:11

25:3,9,14 35:23

39:10 68:8

103:21

let's 6:18 8:7 40:24

68:1 70:6 71:6

72:25

letter 27:3 41:21,25

55:12

letting 46:10 81:13

leukemia 44:1

level 32:4,9 35:20

40:8,17 61:16

65:14 66:10

69:13,15 89:24

101:20 105:13

109:23

levels 22:6 24:1

28:21,25 29:4,5,7

30:23 33:13 34:7

36:19 37:7

39:17,24 40:1,7

43:24 44:2 64:12

67:4 68:12,14

88:8 89:17 97:25

103:18 107:1

112:12

life 23:14 49:19

50:1 69:25 71:15

74:8 77:23 91:8

lifetimes 44:15

light 24:10 28:5

68:20 70:2 98:14

109:6

lightening 9:23

likely 19:23 25:23

101:6 105:19

limit 19:17 28:11

39:5

limitations 14:25

limited 4:23 5:21

14:15 19:14

35:15 101:15

limits 8:9 105:11,12

Linda 2:22

31:19,23 33:21

34:19 40:13

97:20

line 11:17 12:24

linear 70:10 71:21

linked 33:1

links 5:10

list 81:24 113:11

listed 5:13 103:22

listen 58:2 62:12

literally 15:6,21

literature 67:3

litigates 41:16

little 6:7,13 41:24

48:11,13 55:21

58:11 60:17

71:11 76:14

82:5,19 84:1,3,12

87:10,22 98:15

live 46:12 48:22

54:12,15 59:13

lived 79:5

livelihood 85:6

living 62:17 91:25

locate 20:25

located 21:8 22:10

107:11

location 8:10 16:19

locations 34:4 37:1

logical 44:25

logistics 22:8

Lois 63:19,24

long 55:13 56:10

61:13,22 62:5

65:21 69:24

84:10 109:1

longer 8:24

longest 99:4

long-term 48:24

91:7 94:22

loose 110:20,22

loosen 83:20

loosened 44:6

losing 77:23

lot 47:6 52:11 62:20

63:9,18 64:24

76:3 81:3,20 85:7

86:15 87:16,20

93:12 98:1

107:25 113:3

lots 64:1,6,9,10

Louisiana 18:19

love 62:15,25

63:2,6 64:2 69:19

99:2,7

low 7:7 43:24 44:2

86:12
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Lowell 81:12

lower 40:21,24

66:19 97:16

lowering 39:4,12

89:8,24

low-level 90:18

lubricants 7:13

lucky 47:18

lunch 72:25

lunchtime 77:9

lung 73:21

lying 54:13,14

M

machine 84:12

magnitude 19:15

mail 5:11

main 65:21

mainly 47:14

maintain 37:3

104:12

maintained 106:5

111:1

maintaining 44:22

maintenance

100:23 104:11

105:6 106:6

110:25

major 45:21 55:4

69:5 70:19

94:10,19

managed 9:15

management 20:2

27:13 28:8

managing 106:4

mandated 14:2

17:15

mandatory

11:13,24 13:22

15:20 18:12

20:16 94:4,24

95:3,8

Manhattan 31:25

38:2,6 97:16

manmade 67:13,20

manner 8:13 88:14

102:20,21,23

manufacture 43:9

manufactured

103:24 104:1

manufacturing 8:4

Maria 4:6 113:15

Mark 3:21

107:14,15 115:20

marked 11:15

marking 20:16

marriage 114:9

Mary 2:17 18:17

81:16 115:8

Maryann 85:2

masks 74:15

masonry 75:6,15

76:18 79:21

82:1,13

Massachusetts 75:9

Massey 3:3

41:9,11,13 87:10

115:12

massive 16:3 22:23

24:2

mastic 70:9

mastics 70:2

material 7:5 23:24

33:24 76:4 83:23

96:9

materials 102:10

103:4,20

104:12,22 105:17

106:11,21

107:2,4,11 108:8

math 46:24

matter 9:23 23:19

41:19 88:4

114:10

matters 20:2

Maureen 3:18

100:9 115:19

maximum 39:1

may 1:9 5:8,11 7:19

9:7 29:7 32:5

39:3 56:20 74:9

98:22,23

101:7,23,24

102:19 103:7

104:20

105:1,3,23

maybe 78:16 84:10

93:6 94:25

McCabe 88:2 91:14

mean 13:15 25:25

61:18 69:7

means 6:18 8:23

21:2 47:20 56:13

59:25 102:23

measurably 33:13

measure 66:13

measured 14:23

measures 20:15

26:8

measuring 63:8

meat 68:4

mechanical 22:10

media 111:19

medical 105:4

medication 48:24

49:21,24

medications 50:7

52:24

meet 40:22

meeting 1:2 4:14,24

5:5,15,20 6:7

30:15 56:25

74:17

meetings 4:11 5:6

29:23 30:16

61:18 87:21

meets 76:1

member 12:12,16

14:14 16:17

31:22 32:8 33:21

34:19

35:8,10,13,24

36:20 37:15

members 12:19

14:17 17:6 26:20

34:7 37:9 45:18

87:17,24

88:2,6,12

90:3,6,12 107:18

Member's 33:25

membership 18:11

107:23

memorial 81:11

men 83:6,14

mention 86:11 99:1

mentioned 22:11

40:16 55:8 86:7

88:5 97:4 99:2

108:11

met 93:15,17,19

metal 9:25

meter 67:7 84:18

method 31:11

56:11 60:22

105:24

methodology 35:11

methods 28:19

72:10 112:22

Metro 107:19

108:19

metropolitan 69:5

mic 86:21
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Michael 91:14

middle 79:21

97:17,18

Mike 88:2

mild 49:1

mildly 45:4

mile 76:21

miles 14:20 15:23

22:4 72:21

milk 68:4

mill 64:23

milliliters 56:14

million 16:21,22

21:23 24:6 25:5,7

27:25 32:5,7,12

33:13 36:4,22

38:8,10,25 39:5,6

40:3 42:14,19

43:11,16,17

55:15,17 56:24

57:12,15 72:1

78:5 82:3,6 85:22

92:21 110:9

millions 15:21,23

22:21 23:22 58:3

70:15

mimickers 67:24

mind 39:12 99:17

mine 54:10

minimum 98:9

minute 42:9

minutes 5:22

56:10,15 71:7

99:10

Miraculously 52:17

Miranda 3:3

41:9,13 87:10

115:12

mirror 76:5

misconception

19:22

miss 77:14

missed 61:8

mistake 59:23

misused 67:17

MIT 81:20 85:13

86:25

mitigating 105:24

mitigation 28:20

36:6

mix 73:7,10,12

mixed 73:7

mixing 73:11,17

78:15

mockup 83:4

model 28:8

mold 52:16

molecule 72:15

molecules 72:20

Mollette 81:16 85:2

mom 57:7

moment 90:25

moms 54:7

money 27:21 69:17

82:16

monitor 108:12

monitoring 60:23

105:4 110:25

month 11:1 43:22

49:6 85:3

months 30:21 35:5

43:22 50:15

54:19 55:5 74:18

75:7 85:3,4 86:23

Moreover 29:22

morning 73:20

mostly 81:6

mother 46:12 59:3

mouth 76:6

move 45:4 48:6

73:12,16

moved 63:2 64:17

moving 96:4,23

multiple 21:12

musical 82:5

myriad 7:8

myself 49:18 57:9

85:21 98:18

N

naI 59:14

name's 41:13 60:11

nanograms 67:6

nation 37:15

national 2:11 4:6

14:15 21:13

30:22 45:21

nation's 36:2,17

nationwide 28:24

31:4 38:19 45:16

natural 11:23 13:7

26:3

naturally 67:15,21

72:19

Navy 113:4

nearly 16:7 23:1

77:6

nebulizer 49:4,13

52:1,25

nebulizers 53:7

necessary 11:12,13

23:16 42:1

needle 15:6 16:12

25:11

negative 37:7

Neighborhoods

31:24

neither 11:11

networks 15:24

neurological 44:1

Newman 100:16

news 33:23 34:5

47:16 48:8 54:20

85:15

94:14,17,18

nice 79:10 82:5

night 50:11 51:2

54:25 57:1 58:8

59:4 60:1

66:22,23 68:23

79:9

nine 83:8 87:3

NIOSH 56:11

105:11

nobody 58:7 59:16

nobody's 63:17

non 12:23 106:10

nonexistent 82:16

nonleaking 16:25

nonliquid 110:5,14

111:5,14

112:3,7,10,21,23,

25 113:1,7

non-liquid 10:3

no-no 86:8

nonprofit 41:16

non-totally 8:15

102:9 103:9

106:10

nonuse 110:5

nor 11:12

normal 12:19 78:23

Northeast 3:7

64:18

Notary 1:15 114:6

note 48:2 53:15

noted 45:7

nothing 6:10 52:11
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54:2 59:7 60:21

67:15 83:1 94:9

109:25

notice 1:6 4:16

5:2,4,17 6:3 11:5

17:14 19:16

20:15 27:18

29:15,19,24

30:5,6,9,11,17

32:1 41:1,23

42:12 44:18,21

46:4 87:23

100:20

noticed 49:8 77:10

notify 107:11

noxious 90:9

nuclear 113:4

numerous 29:23

nurse 49:4,9,11

50:21 52:2,24

86:3

nurses 50:25

nurse's 53:5

NYCOSG 100:19

NYCOSH

100:13,20 101:10

102:1,13 104:4

106:9,14,17,19

NYCOSH's 100:16

NYS 2:22

O

Obama 31:13

object 102:15

106:12

objective 9:5 13:9

objectives 6:20

obligation 21:25

obligations 24:4

obtain 24:16

obvious 28:10

obviously 62:1

110:8

occupants 51:16

107:11

occupational

3:16,18

100:9,12,21

101:4,8 104:20

105:1,14,15

occur 67:20

occurred 24:20

occurring 67:15

o'clock 71:6

October 39:14 40:1

45:13

odd 7:19

odds 24:18,19

office 2:12 4:9

40:14 53:5 77:5,6

81:7 93:18 99:3

officially 39:14

officials 34:17

89:22

off-sight 29:9

off-white 73:14

Oftentimes 25:25

oh 68:1

oil 12:23 70:16

oils 7:13

okay 60:7 67:21

71:5 77:15 84:22

86:24 87:6 91:19

96:10,18

old 9:19 47:15

75:10,13 77:3,5

older 104:13

ones 77:7 98:3

ongoing 13:1

107:12

op 79:4

open 43:1 48:5 51:9

63:5 84:23

open-heart 73:22

opening 80:14 83:3

openly 37:9

operating 25:2

operational 14:9

18:25 23:18

operations 10:23

19:9 106:5

opinion 23:12

opinions 60:13

opportunities

105:20

opportunity 4:25

10:23 18:15

26:13,23 41:3

74:19 100:19

107:13

opposition 32:9

option 35:2

oral 50:8 60:25

order 17:22 22:3

24:21 28:12

75:11

Organics 2:11 4:9

organization 60:15

organized 48:13

organizer 87:8

organizes 41:17

original 104:5

106:15

originally 15:12

originated 29:9

OSHA 105:10

107:9

otherwise 16:25

24:15,20 95:17

113:13

ours 110:15 113:2

ourselves 78:24

86:11

outages 17:23 24:4

outcome 114:10

outcry 34:16

outraged 27:24

outreach 29:15

outside 5:20 36:17

48:17 69:25

71:14 80:17

109:13

outweigh 24:24

overall 25:13

overdue 61:22

overlapping 48:15

overnight 62:6

overriding 30:5

overstated 15:21

over-the 50:8

overwhelming

19:25

owned 85:23

owner 108:23

owners 20:21,24

P

p.m 1:10 5:15

P.S 33:25 34:6

38:2,6,13 39:22

46:20 58:20,21

paddle 73:10,12

78:17,20

Padmount 22:14

24:20

PAGE 115:3

paint 70:3 94:22

100:25 109:10

110:20,22 111:15
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painted

109:9,10,12,14

paints 7:14 101:16

103:25 113:3

pal 72:24

pale 49:15

panel 26:20 88:6

pant 73:16,18

paper 7:1,19

parent 3:5 38:1,24

46:12 59:22 61:6

62:9 71:1 88:12

96:12

parents 29:19

34:7,16 37:8,12

62:16 63:16 66:6

87:18 88:3 90:23

95:4 96:15,19

participate 26:13

105:3

participation 87:23

particular 58:18

87:15

particulates 54:4

parties 29:16 114:8

partner 27:2

partners 86:3

Partnership 21:14

passed 16:5

passive 35:14

past 3:21 10:20

15:16 19:10

60:15,20 61:15

64:15,17 67:2

107:15,20

pasteurizes 7:14

patents 68:24

path 37:16

pathway 45:19

pathways 45:16

67:25

Patricia 3:5 115:13

pattern 52:23

patterns 54:18

pay 64:4 71:1 93:6

paying 14:22

PCB 3:7,11 4:13,17

6:8 8:15 10:21

11:9,16,22

12:8,10,15,17,21,

23 13:3,16

15:3,4,8,13,17

16:2,14,19

17:3,8,19

18:4,5,8,23,25

19:2,5,7,13,21

20:1,13,17,19,21,

22

21:2,4,7,9,11,19

22:6,10,11,13,18,

20 23:1,7,8,13

24:22

25:1,8,12,13,16

26:1,4,25 27:4,13

28:6,13,16,21

29:1,2,3,7,17

30:7,13,18,23

31:1,3 32:3,16

33:12,16,18,22

34:18 36:3,19

37:7 38:7,21

39:4,18 43:14

44:4,16 45:16

46:6 54:21,22

56:22 57:21

58:14 59:5,19

60:21 65:6 66:22

68:12 70:16

76:19 86:14,19

87:14,16 88:9

89:10,25 90:12

91:8,16 94:4 98:3

100:24

101:12,16,20

102:8,9,13,17,19

103:1,7,18,19,20,

22 104:6,9,12,22

105:7,9,17,22

106:11,15,19,21,

24,25 107:2,4,11

109:10 110:5

111:5,16,25

112:13,17,23

PCB-contaminated

88:10

PCB-exposure

88:22

PCBinschools.org

93:25

PCB-laden 38:4

PCBs 1:4 4:22

6:14,18,23 7:3,6

8:2,5,13 10:2,4

13:1 19:23 21:15

23:11,20 24:2

25:5,7,22,24

27:7,25

28:4,11,19,23,25

29:4 30:24

32:10,15,18,21,2

4 33:24

34:5,21,23 35:20

36:23 37:14

38:18 39:4,17,24

41:19,22

42:16,22

43:10,23 47:4

53:11,14 54:21

55:15,17 56:16

57:8,12,15,16

59:21 60:23

61:1,3

64:1,2,5,21,25

65:14,17,18,22

66:2,9 67:20 68:7

70:5 72:2 78:5,25

79:7,8 80:22,24

81:5 82:7

85:2,17,25 87:1

89:11,15,17,20,2

3 90:14,18,20

91:10,13,20

94:23 95:8

96:4,25 98:1,2,12

99:8,15 100:3

101:7,13,17,23

102:25

103:2,10,15,23,2

4 104:1,17

106:10 108:6,17

109:5,22 110:14

111:14,19,21

112:3,6,8,10,12,2

1,24,25 113:1,7

peer 60:16

peer-reviewed

43:23 60:24

people 32:16 44:24

45:7 53:10 62:16

63:6,18,20 64:10

65:5 67:14 68:9

71:10 72:18

77:2,10,11 78:6,7

79:5 80:20

81:2,21 85:7,13

86:15 98:6

101:25 110:1,9

111:3

people's 65:1

per 15:9 16:10

25:5,7 27:25

32:5,7,12 33:13

36:4,22

38:8,10,25 39:5

40:3 42:14,19

43:10,16,17

55:14,17 56:24

57:11,15 67:6

72:1 78:5 82:3,6

85:22 92:21

107:8

percent 34:24

51:19,20 69:8

79:22

percentage 11:16

23:10,12,25

25:12 51:21

perfectly 16:25

24:15
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performed 34:9

perhaps 13:19

period 10:5,12

19:18 20:7,11

30:21 34:22

96:21 97:2 99:21

periods 39:21

permissible 105:11

persistent 89:16

person 65:9 85:12

personal 105:9

107:3,6

personnel 93:18

persons 102:19

pertaining 102:8

105:16 106:19

pertinent 113:1

Pesticides 2:6 4:3

ph 77:8 78:20 81:16

87:2 88:2 91:15

103:12 107:21

phasedown 18:10

phaseout

11:10,13,15,24

12:1,7

13:7,12,20,22

14:2 15:2,11,20

16:14 17:8,15,19

18:12 20:16 21:9

26:4

phenomenal 64:16

phenomenon 34:19

phone 72:24

physical 14:9 15:25

22:8 32:17

pick 50:6 52:4 53:6

92:14

picked 49:13 92:10

picture 63:4

piece 16:1 17:5

21:7 23:1

24:16,17,22

26:2,10 76:14

85:1 92:7,10

pieces 7:12 15:5,21

21:22 22:3,9,21

23:22 77:16

pigments 7:15

pilot 35:8,16,23

36:25 40:13 45:9

88:21

pipe 80:11

placement 103:3

places 97:3

placing 17:25

plan 17:9 20:25

27:13 28:9 88:23

planned 90:16

107:12

planning 4:13

21:24 32:4

plant 21:17,18

101:14

plants 21:16 113:4

plasticizing 104:2

plays 48:13

please 50:4,6

plenty 43:15,21

pliable 47:8

plus 22:4 44:3 64:6

95:2 110:25

podium 74:21

point 6:9 8:20

13:19 17:12 18:2

24:8,25 42:14

47:4 57:13

73:21,25 80:6

93:7,24 94:17

96:19 101:25

pointed 10:5 44:24

points 14:8 44:17

111:12 113:2,6

pole 22:14 24:13

political 59:10

politicians 94:1

pollution 2:13 4:10

90:7

POLYCHLORINA

TED 1:3

polysulfide 73:2

75:13 76:9

77:22,23

poohah 87:2

population 9:12

39:23 40:9 47:1

69:9 105:18

populations

30:4,21 104:10

portion 44:18

portions 31:24

77:14

pose 9:7 22:8 89:11

110:16

posed 14:18

poses 11:5 45:20

position 19:3 103:8

104:5 106:15

positioning 21:1

positive 35:9 37:10

76:16

possibility 78:1

possible 24:22

84:15 101:22

102:1

possibly 57:2

74:7,9 80:12 89:8

94:22 102:25

post 47:1

postmitigation

111:1

Poswer 18:19

potential 4:17

24:24 32:2

101:7,8 103:6

112:6,16

potentially 14:6

20:8 100:24

104:10

pounded 61:11

pounds 7:3 21:15

72:2

power 2:18 11:19

17:25 19:4 21:16

22:2 24:5 26:12

109:6

power-activated

24:14

ppm 28:11 30:12

61:16 64:8

66:10,13 67:5,6

69:9,13,18

89:18,20

92:11,20 94:7

96:5 101:18,20

103:15,18,21

109:23

ppm's 96:7

PPT 61:3 64:25

66:18

practical 11:11

12:2 20:5 22:19

23:18,19 25:17

112:17

practically 13:21

practice 48:16 76:7

78:23

practices 105:9

107:6 108:2

prance 66:11

precious 26:24

precisely 20:22

106:6

predates 103:4
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predetermine 37:4

predetermined

28:15

preemptively 36:6

prefer 89:2

pregnancy 48:4

pregnant 48:3,7

51:22,23 55:20

premature 17:1

24:18 111:18

prepare 29:25

prepared 76:25

88:1

preregistered

113:11

Preschools 91:8,16

present 4:25

8:13,16 26:14

28:25 32:18

88:18 91:3

107:13,14 111:2

112:12

presentation 5:16

72:17 101:1

presentations

5:18,21 60:25

62:23

presented 89:18

presenting 100:13

presents 43:11

president 2:20 3:21

26:18,21 27:2,23

38:2,13

107:15,20 108:25

press 93:14

pressing 11:25

pressure 100:6

presumed 42:14

pretty 61:11 67:2

69:4 71:3

Prevention 2:13

4:10

previous 31:12

37:11

previously 40:16

primarily 102:14

106:12

principal 2:17

50:23 51:6 52:6

53:24

principals 99:24

Principle 18:18

principles 72:8

printed 29:20

prior 53:16 112:13

Priorities 21:14

privacy 86:9

private 3:13 91:18

proactive 21:11

26:3

probably 7:11,25

40:10 43:18

66:11 71:16

77:21 99:4

problem

27:9,15,16,22

30:25 31:4,7,11

46:5 54:5 66:14

67:11,24 68:17

69:2,3,6 74:5,6

77:22 81:18

85:15 86:12

92:17 97:9,14

98:8,9,17 100:3

102:11

problematic 19:20

20:14 23:19

problems 49:2 74:2

86:10,12 98:3,23

100:6 108:16

110:2

procedures 12:20

34:13 107:1

proceeding 5:18

PROCEEDINGS

4:1

process 8:4 26:14

34:14 47:7 59:9

61:12

processed 64:20

processing 43:9

produced 7:4

product 69:25 70:7

82:12

production 23:8

products 68:16,18

69:12,21 70:4

101:20 102:9

103:19,22,23,24

104:3

Profess 43:3

professional 18:24

114:5

professionals 19:11

74:15

professor 2:24

38:14 45:14

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program 2:11 4:7

6:8 16:4,16 18:4

27:6 35:8,16 87:8

88:21 106:6

107:10

programs 11:21

13:2,14 18:10,13

104:15 105:4

106:20,23

progress 11:14,20

prohibited 103:10

project 34:10 48:9

55:4 58:12,24

64:19 65:2 85:10

projecting 29:5

projects 62:13

101:6

prolonged 17:23

promised 60:11

71:5

promoted 111:6

promoting 12:7

promotion 18:10

promulgated 15:12

16:7 34:11

104:23

promulgation

11:10

proof 76:16

proper 37:16 107:8

properly 72:13

73:13 75:17

properties 7:6

104:2

property 84:24

109:3,4

proportions 31:10

proposal 17:13

33:19 36:22 44:6

proposals 45:2

propose 45:17

110:20,24

proposed 1:6 4:16

5:2,17 6:3,10,11

8:17 10:8 11:11

16:14 19:16

27:18 32:2 33:10

36:18 87:15 90:6

101:15 110:18

111:16,18,22

proposing 110:22

prospect 90:24

protect 59:13,15

70:24 71:1 72:5

104:24 106:7,8

protecting 44:16
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59:16,24 64:25

protection 2:10 4:8

26:24 39:7 43:19

99:6 101:11

105:13,21 106:7

107:9 108:3

protections 40:17

44:23 89:9,25

90:25 91:6,10

protective 39:11

46:1 102:4

103:14 104:21

105:3,10 107:7

protocol 93:23

protocols 34:11

proud 21:20

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provide 4:25 5:8,23

14:21 19:18 20:9

21:25 24:5 26:21

30:15 87:12

105:8,12

provided 8:13

12:13 101:10

provides 5:10

providing 4:21 5:7

101:4

provision 41:1

107:8

provisions 41:23

42:4,7 44:20 46:4

proximity 90:8

96:23

PS 97:12,15,23

PTA 38:1,2,13

56:25

public 1:2,15 3:3

4:11,25

5:6,7,18,19,25

6:12 9:9 10:12

11:20 12:4 13:11

14:22 27:13

28:4,8 29:22

30:1,3,6,8,14,15,

18,19 31:2

34:7,17 37:18

39:16,17,25

41:1,9,14 45:6,23

70:20 72:5

87:9,23

88:7,11,21

94:1,25 99:24

102:4 103:1

105:13 106:1,8

114:6

publication 29:21

36:10

publications 60:25

publicized 36:9

publicly 5:24

published 27:18

29:14 112:9

pull 56:3 59:4 60:1

84:2

pulled 52:8 56:6,19

pulling 83:19

pulmonologist

53:25

puncture 24:15,17

purely 43:5

purifier 54:1

purpose 4:24 28:2

36:1

purposes 9:21

push 98:21

pushed 83:24

pushing 79:25

putting 64:8 70:9

80:9 82:21 83:3

91:7

Q

quality 91:7

QUANTECH 2:2

quantification

28:21

quantify 29:6

quarter 71:19

quarterly 8:8

question 27:20

42:16 55:22 56:5

96:21 109:24

110:3

questions 5:3 11:5

20:1 30:14 41:17

107:23

quick 6:6 81:17

quickly 7:21 8:19

109:6

quite 9:10 59:9

61:20,21 68:25

73:24

quote 39:6

89:15,16,18,19

102:19 103:14,20

R

racing 49:23

radiators 53:11,12

56:18

rag 78:20

raised 18:2

raises 19:25

raising 32:9

Rambis 93:10

range 37:2

ranges 66:19

rapidly 12:11

rat 67:5

rate 9:17 13:5

14:22 33:7 56:16

rather 36:9,11 90:5

91:2 98:19

rational 29:2

rationally 42:9

rats 67:3,6

raw 73:20 76:4

rays 77:24

reach 12:1 84:5

108:5

reached 45:8

reacted 54:11 109:6

readily 20:18 22:19

reading 54:19 76:8

reads 29:21

ready 51:16

reality 102:5

realization 34:18

realize 63:20 69:17

80:21

realized 62:16

really 13:21 38:23

40:16 48:7 57:6

59:25 60:7

63:11,18 65:6

66:8 68:25 69:24

71:25 73:3 74:12

81:22 83:17

85:16 100:25

reason 29:10 41:20

46:16 47:25

58:19 81:23

82:11 101:22

reasonable 12:2

27:17 69:13,15

reasoned 22:17

reasoning 36:12

reasons 41:24 43:5

90:5 102:3,7

reassess 8:17

reassessing 33:15

67:9

reassessment 1:4

4:12,17 32:3
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61:23 62:15

63:10 101:16

reassessments 64:5

reassessment's

61:22

reauthorization

61:12

received 5:5 21:12

receiving 47:24

recent 90:2 107:22

recently 88:19

112:14

recognize 14:8

recognized 20:23

22:25 39:15,19

45:18 112:20

recommend 30:19

108:10

recommendation

53:17 58:6 96:5

recommended

105:11 112:17

reconsider 36:22

reconsideration

46:3

reconvene 71:7

recorded 34:6

recordkeeping

70:13,17

record-keeping

107:4

rectifier 21:20

recycled 25:3

recycling 9:25

red 73:14

red-blood 73:20

reduce 12:15 36:2,6

72:8 96:7

112:18,22

reduced 15:19

reducing 21:4

105:22

reduction 12:12

redundant 47:3

refer 17:14

referenced 102:18

referred 15:13

16:11 40:14

45:14

refrain 87:11

regard 39:17 104:8

regarding 4:22 5:1

19:7 36:3 42:7

101:12

regardless 29:8

102:20 104:6

106:15

region 1:12 2:8 4:5

45:8 61:19 92:6

111:10

Register 5:4,13

9:11 27:19 36:10

Registered 114:5

regular 107:2,3

regularly 89:13

regulate 8:3 31:7

59:21

regulated 19:19,21

20:13,19,22,25

21:5,8,11 22:6,9

23:1,14 24:1,23

25:1,9,12,16 26:5

regulation 17:20

28:23 33:10

38:22 58:4

101:21 103:20

104:4 106:9

regulations 7:4

10:22 11:9 12:9

17:23 19:8 20:21

21:3 29:3 43:7

44:9,10 46:6

91:11 102:2,8,14

105:16 106:18

108:5 111:13

regulations.gov

5:11,25

regulatory 27:22

32:9 36:18

89:9,17 102:15

106:12 112:2

rehabilitated 34:22

reimburse 93:6

reiterate 10:25 18:7

reiterated 103:8

relate 10:22 19:8

91:10

related 20:2 21:4

26:4 30:14 48:24

49:4 56:21 114:8

relates 87:15

relationship 91:21

relax 98:17

relaxed 98:10

relaxing 45:24

release 19:23

25:13,22,24

104:17 105:20

111:24

released 7:5 90:17

releases 24:19 25:8

38:7

relevant 42:15

reliability 17:25

22:8

reliable 14:21 21:25

24:5

Reliance 104:20

relies 70:22

relieve 28:12

relieved 51:24

relieving 28:3

rely 22:2

relying 36:9 106:7

remain 35:20

remaining 5:6

11:18 15:3 16:2

22:13 25:12

remains 23:2 35:2

remarkable 13:14

remarks 41:11

remediated 113:7

remediating 28:4

remediation 37:8

57:24 88:23

97:24 101:12

remember 15:11

63:4 75:10 80:9

84:11

remind 12:5 18:20

removal 11:15

13:15 21:22

28:16 34:13

82:14 107:2

110:21 111:19,23

remove 9:1,19

12:25 21:12 27:7

30:12 40:25 94:7

103:17 112:21

removed 12:17

13:6 38:10 40:3

70:5 75:13 83:4

88:11 89:20 92:4

103:8,16 111:21

112:24

removing 6:17 8:22

11:17 18:8

21:6,15 28:13

80:7 110:20

render 35:23

renovation 38:4

47:17 49:7

rented 86:25
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reoccupying 63:6

repair 8:9 75:2

repeated 59:23

repeatedly 49:9

repellent 110:24

replace 9:20 104:12

replaced 26:1 38:11

97:6

replacement 13:16

14:5 24:3 34:10

75:6 97:13

replacing 97:23

98:12

report 73:1,2 76:8

Reporter 114:6

Reporting 1:14

reports 90:16,19

represent 88:9

100:22 107:24

representative 57:1

representatives 5:2

representing

31:19,22

represents 31:23

reproductive 7:24

85:23 90:22

request 10:25 28:9

30:12

requested 11:3

requesting 41:22

requests 101:17

require 11:6 13:25

14:2 17:23 23:21

24:2 25:18 27:12

31:5

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17:22 20:21 26:9

27:7 103:17

111:21

requirement 13:2

15:11 17:5

requirements 26:7

requiring 34:20

research 28:6,14

60:21 62:13

64:6,7 65:12,22

67:8,10 72:6

85:20 108:4

researcher 62:10

residue 75:12

resistance 7:7

resource 14:18

26:24

resources 14:15

23:13 31:6

112:20

respect 30:18

respectfully 19:24

30:9 40:25

respirable 72:14,18

76:23

respirators 83:8

105:2 107:8

respiratory 107:9

108:16

respond 20:5

109:19 110:2

response 11:4

19:19 20:3 34:16

63:11 97:21

99:14

responses 63:12

responsibilities

20:4

responsibility

36:14

responsible 18:25

88:14

rest 44:20 76:12

88:14 92:14

restrictions 8:9,10

restrooms 5:20

result 11:23 12:9

13:4 39:6

resulting 26:9

101:7

results 36:24 37:4

40:7 58:14 92:12

resume 37:16

retired 3:9 72:22,23

77:3

retirement 12:19

17:1 21:19

retreated 103:13

retro 12:23

retrofit 104:13

returned 12:24

37:7,10

reuse 9:16

revert 104:5 106:14

review 38:20,21

60:16

reviewing 107:22

108:3

revise 102:13

105:16 106:9,18

revision 102:15

106:13

revisions 101:22

revisit 11:9

Richard 3:15 96:11

115:18

riding 48:18

rig 77:17

rights 41:15 72:6

rigorous 36:11

ripped 53:13

ripping 54:25

ripple 14:5

risk 8:6,14,16 9:2,7

15:15,16 16:24

18:1,14 24:23

25:8,13,16 26:8

43:11 65:25 66:2

88:22 89:12,19

91:8,14 105:20

110:16 111:3,25

112:6,16

risks 25:14 35:3

89:22 90:15

104:8,11

River 21:18 64:19

99:9

road 72:21

Rod 77:11

Roewer 2:15

10:13,14 23:4

115:7

rolling 93:22

roof 109:5

room 1:13 5:20

44:21 47:11,13

48:1 52:8,23 54:2

55:20 58:7

rooms 56:17

Rose 60:19

Rosenthal 2:22

31:19,23 32:8

34:19 35:8,24

36:21 37:15

97:20

Rosenthal's 33:21

40:14

routes 65:23

routine 107:25

routinely 36:16

RPR 1:14

rubber 7:13 83:23

84:1

Ruben 26:21 27:2

rug 27:22 52:8,9
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rugs 59:6

rule 6:10 8:12 10:8

11:11 14:15

rulemaking 1:6

4:16 5:2,17

6:4,10,16,20 9:8

19:16 20:7,10

26:15 27:18 32:2

41:1 87:15 95:7,8

100:20 111:18

112:5

rules 22:18

ruling 39:4

run 5:15 55:23

64:23

rundown 6:6

runner 82:21

running 48:17,18

52:18 53:21

S

Sadly 36:10

safe 51:8,11 56:23

58:7 69:10 105:9

107:6

safeguard 39:2

safety 2:12 3:16,19

4:9 22:8 24:7

34:12 36:3

37:1,17 58:4

100:10,12,21

101:4

sake 6:19 37:12

salt 79:15

salt-installed 77:8

sample 22:3 23:23

24:12,16 71:22

76:13 77:25

79:16,17,18 82:2

84:8,9 85:11

sampled 24:21

92:10,24

samples 56:9 64:21

70:23 71:23,24

77:18,19 78:2

79:4 81:4,6 82:1

85:25 86:5

91:23,24

samples/200 64:22

sampling 24:3,7,9

26:6,9,10 92:22

93:11 106:23

107:3

sand 82:4

sat 61:19

satisfy 26:6

saw 54:20

76:5,18,22 77:9

84:4 94:16

SCA 56:8

scaffolding 49:6

scale 14:14 17:21

18:4

scared 52:3

scarifying 75:14

scary 68:25

scenarios 106:18

schedule 17:25

30:15,19

scheduled 29:16

87:22

scheduling 29:22

school 2:25 27:5

28:4,8,12,17,22,2

5 29:1,9

30:4,21,23 31:5

32:19,25 33:25

35:19,21 36:25

37:18 38:5,6,17

39:20 40:3,5,6,15

46:17,20,23

47:10,12,17

49:4,6,9,16

50:10,14,20,24,2

5 51:2,3,8,15,18

52:2,15,17,21,22

53:3,13,15,19

54:8,16,24

55:21,23

56:1,8,22

57:1,16,25

58:17,18,25

59:15,17,18 60:1

69:3 72:5

75:1,2,4 76:20

79:2,7 81:12

84:11 85:9 86:12

88:4,7,8,17

92:2,3,8,13,14,25

93:7,8 94:2 95:3

96:12,16,17,20

97:4,8,16,17,19

100:23 105:5

schools 3:11

27:1,7,13

28:7,13,19,24

29:18 30:8,19

31:2 32:6,25

33:23 34:21

35:16,17

38:18,22

39:11,17 40:18

46:7,25 47:2,7

58:1 59:24 66:7

70:20 76:15

81:2,3 85:18

86:20 87:14

88:11,22 90:12

93:11,12

94:15,16

95:1,8,11,19

98:2,6,8,16,22

99:25 101:24

102:18 103:1

112:14,25

Schreiber 2:2 10:11

18:16 26:16

31:18 37:21 41:8

60:5 71:5 86:17

87:4 91:17 96:10

100:8 107:14

113:10

science 43:15,18,21

44:5,7 90:3

96:13,16,20

97:18 107:1

112:19

science-based

36:12 102:16

106:13

scientific 28:1

33:16 35:22

36:15 39:8

45:15,21 90:5

102:6

scientifically 89:11

scientist 52:10 71:2

scientists 53:9

66:11,12 89:21

scope 19:14 27:16

30:25 56:12 57:5

scratching 73:19

seal 83:19,20,22,23

search 23:13,15,17

68:24

season 50:18

seasons 48:15

second 11:8 13:19

28:18 45:5 50:4

73:24 80:15

82:20,23

Secondly 20:13

section 8:1,11

41:15 95:20

103:12

sector 17:24

seeking 28:10

seem 33:9

seemed 50:13

seems 73:16

seen 50:1 64:11

68:7 69:7 72:3

78:10

self 58:3
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send 59:15 84:12

senior 18:24

sense 25:10,18 30:5

69:24 105:25

110:11 112:18

sensible 43:19

sensitive 95:2

sent 78:3 92:11

September 46:19

series 30:15

serious 31:9 33:3

seriously 21:10

46:2 100:2

seriousness 27:15

serums 68:7

serve 13:11 35:17

106:1

served 18:23 19:1

service 12:24

13:1,6,16,24,25

14:6,22 15:23

16:24 18:9

21:12,16

22:1,5,12,15,21

23:5 24:1,11,24

83:24

services 47:24

sets 21:20

setting 110:18

settle 69:19

settled 64:11

settlement 27:11

88:20 89:7

seven 83:6,14 107:4

several 9:9 51:22

60:25 61:2 73:8,9

88:21 93:4,18

99:4

severe 88:17

shaking 52:2

shaky 49:23

shampooed 52:8

share 46:15

shared 51:6,12

53:23

shares 18:8

shelter 107:20

ships 113:4

shockingly 33:19

shoe 57:3

shooting 9:24

short 11:13 20:7

30:5,6 55:13

shortages 14:7

short-term 7:21

showed 83:18

showing 108:15

shown 7:25 18:9

67:3

shows 7:1 30:7

39:23 43:23 64:8

Shreveport 18:19

shrink 15:4

shrinking 15:8

shut 81:15 85:2

sick 49:15 50:5

52:1 54:7 55:3

109:18

significant 12:10

14:8 18:1 21:3

31:5 89:11 103:7

significantly 11:6

16:13 104:17

silica 72:8,14,15

76:19

silicon 75:12,16

similar 36:11

106:22

Simons 2:10 4:7

6:2,5,6 115:6

simplicity 6:19

simply 11:24 13:18

18:3 20:4 22:19

25:24 26:1 44:7

79:19,24 107:21

sincere 37:13

Sincerely 91:14

single 57:15 59:4

sit 49:16 58:2

site 62:24

sitting 53:8 66:3

situated 14:24

situation 95:25

situations 110:14

six 50:15 53:2

57:20 107:4

six-to-10-year-old

40:11

size 14:12 33:5

sized 81:12

skateboarding

48:18

skin 7:23 49:20,22

71:14

slated 82:13,14

slide 7:1 63:19 68:2

slides 65:10

slightly 46:11

slippery 84:1

small 9:14 14:14

17:2 23:25 25:12

76:22 112:25

smaller 16:21 33:5

smallest 72:20

smart 80:20

smoke 78:11

smooth 76:3

snuck 71:10

soap 84:1,4

soapy 83:22

sobering 59:9

society 89:22

Sociology 60:19

soil 57:18,24 68:4

82:2,7

92:17,19,23 93:3

solely 36:9 102:2,14

106:11

solicited 27:24

solicits 9:8

solid 10:15 63:13

solid-resistance

110:23

soluble 67:22

solution 27:17 31:8

somebody 59:21,22

someone 7:18 51:10

59:3 86:6

someone's 57:3

sometime 10:9

somewhat 57:19

son 63:21,24 92:1

sons 91:25

son's 54:1 92:3 93:8

sorry 79:12 86:22

sort 51:3 78:13

sound 7:19 82:5

Sounds 47:9

source 81:5

sources 29:10 59:21

southern 47:12

space 80:14

spaces 101:9

span 14:19
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26:16 31:18

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91:17 96:10

100:8 115:3

speakers 2:5 102:13

113:11

speaking 17:13

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special 47:21,23

48:2

Specialist 2:10,17

4:8 18:18

specific 33:19 64:24

66:17 105:2

specifically 8:2,10

103:9 108:6

speculate 37:9

speculative

98:20,25 100:1

Speeding 11:17

spent 82:15

sperm 86:13

spill 9:22 25:24

26:1

spilled 109:5

spills 16:24 26:8

spoke 50:23 84:8

87:10

spoken 5:23

sponsors 35:1

spontaneously

42:22

sport 48:13 52:19

spread 14:11

spring 38:16

square 14:19

ss 114:3

St 21:17 60:19

staff 20:2 35:4

37:13 66:7

stairs 83:6 84:16

stake 20:10 91:12

stakeholder 71:2

stakeholders

29:15,25 94:1

stampede 80:7

stance 103:14

stand 95:5

standard 6:17

27:25 32:12

39:13 40:21,23

41:2 42:15,20

43:5,19 45:25

107:9

standards 8:22

30:13 33:16,18

35:11,22 36:3

37:3 98:9,17

104:20,22

stands 32:8 33:19

start 10:7 16:12

63:9 65:19,24

69:16 70:8 74:22

78:18,21 85:4

95:16 96:8 99:23

started 46:19 49:10

81:4,9 82:10

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93:10,11,21

starting 54:7

state 1:15 4:21

19:24 21:7

31:20,22 34:11

35:25 62:14

63:22 92:20

93:2,5,17,19,20

97:21 99:3,12

112:15 114:2,6

stated 17:21 39:3

statement 87:12

88:1 103:1

statements 42:2

Staten 46:13,20,25

97:13

states 16:17 22:22

32:11 94:9

95:10,21 96:1

102:19

State's 93:22

station 83:25

status 35:18

stayed 81:21

steadily-growing

33:11

steep 13:10 16:4

step 35:9 36:25

45:11 95:16,18

112:18

stepping 60:9

steps 27:9 89:3

steroid 49:22

steroids 49:15 50:8

stewardship 37:16

stick 86:11 96:6

sticky 80:4

stifling 47:13

stimulus 104:14

stock 82:23

stockpile 94:21

96:8

stone 77:20

stones 76:1

stop 70:11

stopped 81:10,12

stops 48:19 52:20

stored 9:16

stories 77:8

storm 109:2

story 34:6 46:15

50:3 55:13 59:25

108:22

strapped 53:7

strategy 11:2 12:13

street 2:3 76:21

94:20

strengthen 33:17

strides 21:4

strikes 9:24

striking 45:3

stringent 37:11

stronger 23:17

strongest 41:22

strongly 30:10 46:3

96:6

struck 73:3

struggling 108:5

student 74:22

81:20

students 37:12

81:23 88:22

96:22

studied 38:18 39:9

studies 7:25 28:20

51:7,9,25 57:18

58:13,22 67:1,3

90:16 94:18

95:23 108:15

stuff 9:16 63:8 64:1

73:7 78:14,22

79:11 80:21 92:9

94:23

subjugated 36:16

submit 5:14 42:1

submitted 10:6

11:1 41:21 95:5
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subquestions 9:11

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subsidiaries 25:2

substance 4:3 27:8

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substances 2:7 6:16

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substantially 39:6

substitutes 10:2

success 13:1,14

18:13

successful 12:25

109:1

sudden 92:21

sued 88:12

suffer 29:8

sufficient 29:16

suggest 39:10 96:6

suggested 26:7

suggesting 17:15

Suite 2:3

suits 77:11 83:7

sum 85:16

summarize 110:12

summary 109:20

summer 52:18

64:20 75:7

summertime 75:4

superintendent

84:19

supply 14:5

support 43:6 44:5,7

supposed 66:4

sure 12:20 27:1

51:8,11 58:6

64:25 66:11 93:2

Surely 35:17

surface 75:16

108:18

surfaces 110:23

surgery 73:22

surprised 89:6

surreal 53:6 59:12

suspect 90:2

sweep 27:22

sweeping 81:14

swimming 52:19

switches 70:2

symptoms 33:3

53:4,20

system 18:1 21:5,8

22:16 23:6,23

28:8 72:11

90:20,22

systematically 35:2

systems 9:15 12:18

14:19 17:4 19:22

20:19 21:1 23:7

28:12 32:24

T

tabled 61:17

tag 55:25

taking 4:20 36:25

58:7 66:1 67:8

78:7 82:12 83:2

84:7

talk 6:13 59:20

79:8 82:6 84:7

91:20 113:12

talked 85:5

talking 43:8 44:15

63:1 65:24,25

66:3 84:18

target 69:18

task 62:5

tasks 105:19

teach 38:14 41:5

teacher 62:11

teachers 37:8,12

48:1,3 50:24

51:18,22,23

55:7,20 66:6

74:21 100:22

Teaching 47:21

Team 47:20

tear 82:8

technical 42:10

66:24 101:10

techniques 61:2

technology 64:15

65:3

Teesler 81:16

temperatures 48:25

ten 5:22 30:4 62:15

ten-minute 5:19

tens 22:20 78:15

terms 14:12 18:14

41:22 43:17 45:1

97:7 99:5

Terrace 46:20

terrible 31:8 40:20

territories 13:24

territory 22:5

test 13:23 17:5

57:23 58:16 65:4

89:2 94:10,11

98:6,22

Testa 103:12

tested 29:13 34:4

55:14 56:6,21

57:10,22 58:25

59:17 69:8,9 85:1

94:15 96:25

109:18

testimony 12:12

19:13,17 26:21

97:12,14

testing 15:25 16:4

17:22 18:4 31:1

34:9,21,24

35:14,15 39:22

40:7 56:10 58:15

68:6 94:4,24 95:8

108:12

tests 35:12 37:4,6

89:2

Texas 30:2

textual 43:6

textually 44:20

thank 4:18 6:1

18:15

26:12,16,22

31:15,18,21

37:19,21,23

41:2,4,6,8

46:8,10 60:3

86:17 91:16,17

100:7 107:12

108:20 113:8,15

Thanks 6:5 10:11

87:4 100:8

that's 7:20

44:9,11,13 55:21

61:7 62:9

63:15,22 65:6

66:7 67:7,24

68:17 71:2,22

72:3,17

73:4,18,24 75:8

76:10,22

77:20,25 78:12

81:1 82:9 83:17

84:7 85:14,22

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92:7 94:5,10,12

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They'd 79:17

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Thirty 23:15

thorough 11:4

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thoughtful 11:4

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thousand 93:4

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94:21

threat 31:9 45:19

threaten 85:5

threats 85:5 90:9

three-decade 37:2

three-to-six-yearold 39:23 40:9

threshold 42:15

44:6 89:10 90:14

throughout 22:4

32:25 41:18 59:5

76:11 95:9,21

104:19

throw 79:10 81:14

throwing 76:19

thrown 81:11

thus 103:11

tie 77:10

tie-back 83:7

tight 83:19

tiles 70:2,10

till 75:4

timetable 6:21

tip 98:7

tire 83:25

tissues 28:21

today 4:19 6:1

10:24 16:10 18:3

23:2,17 24:1 25:9

26:23 38:1,23

39:11 46:11,14

58:15 59:11

60:14 61:4,8,11

62:4,21

63:4,16,25 64:16

68:16 69:14

75:17

87:12,17,19,25

97:12 100:13

103:5 107:18

today's 5:5,15,23

36:9

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tolliwall 78:20

Tom 2:10 4:7 6:2,6

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ton 79:3

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71:24

tool 72:11 75:14

76:2

top 22:14 24:13

97:17

topic 29:17

topics 9:11

topsoil 57:21

TOSCA 8:2 11:9

61:16 62:19 64:5

67:9 68:13

70:5,18

total 21:15 23:4

44:4 57:24 64:25

102:23

totally 27:20 29:24

102:21

touching 32:18

tough 85:17

toward 77:22

towards 96:4

toxic 2:6 4:3 6:15

27:7 34:3 43:23

62:17 63:2,25

89:15 103:4

toxin 44:23 88:17

toxins 33:17 56:23

90:7

toys 59:6

trace 83:16,17

track 25:11

trade 10:16,18 19:4

traffic 90:8

train 61:9 99:24

trained 72:7 104:25

training 72:7 101:5

105:2,8 107:5,8

108:7,10

Transatlantic

21:18

transfer 7:10 9:14

transform 101:13

transformer

9:20,21 21:19

transformers 6:19

8:8 9:13,25

12:18,21

22:11,14,15

24:12,13,20 25:3

42:8 66:1 68:19

69:25 70:16

transient 29:4

transmission 10:19

15:23 19:5

transmitters 14:10

traps 80:4

treat 53:17

treated 53:14 80:22

109:22

treating 63:7

treatment 49:4

50:5 101:14

treatments 49:13

52:1,25

trigger 51:3 52:9

53:19

triggers 52:13

trimester 48:4

triplets 61:7

trips 52:2

troubling 54:16

99:1

truck 76:5 84:23,24

true 20:20

truly 34:18 76:24

try 52:7 59:13

86:13

trying 65:8 66:4

99:7

TSCA 111:13

TSCA-regulated

111:14

tube 80:17

Tuesday 1:9
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turns 43:4

twice 93:15

twist 71:11

type 13:19 16:19

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U

U.S 2:8,13 68:24

ultimate 12:1 26:4

ultimately 13:9

98:23

ultra-low 61:3

unabridged 100:17

unacceptable 97:25

unachievable 13:9

unauthorized 94:8

101:19 102:8

104:7 106:16

unaware 99:22

unbeknownst 66:5

uncomfortable

52:3

uncovered 9:17

undermine 45:3

87:23

underprepared

77:1

understand 21:21

30:25 31:3 50:22

57:22 70:14

95:13,17

111:15,16

understandable

44:9

understanding

14:7 33:17 37:14

45:22 65:6 67:11

112:11,19

undertake 24:2

undertaken 17:16

45:20

undertaking 16:3

17:7 22:7,22

32:10

underwent 37:1

undetermined 36:5

undisputed 89:11

undue 28:3 32:6

101:24

unenclosed 42:20

unenforceable

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unfortunately

31:25 63:14

112:11

union 71:13 86:8

unions 100:22

unique 14:25

unit 15:9 16:10

United 16:16 22:22

95:10,21,25

units 9:18 23:7

78:16,17

universe 15:8

25:1,16,19

University 2:25

38:16 85:23 86:4

unknown 15:4 18:6

31:9

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113:13

unlike 46:25

unnecessary 13:20

18:12 22:7

unplanned 17:23

unquestionably

16:11

unreasonable

8:6,14,16 9:2,7

25:16 43:11

89:18 110:16

111:2,25

unrecognized 81:5

unusual 48:21

106:3

unwarranted 18:14

update 12:12

updated 17:9

updates 33:16

updating 16:10

upon 35:19 103:8

111:23

upper 31:23 64:20

99:9

upset 63:18

urge 30:10 46:3

91:4

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104:4

106:9,14,17,19

useful 23:14 112:10

usually 48:23

USWAG 2:15

10:13 12:16,19

14:16 17:6

18:8,15 19:2,4,5

22:23

utilities 10:15,17

12:14 13:2,8,22

14:20 15:1 16:18

18:1 19:20 20:15

25:18

utility 13:10

14:9,12 15:1

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utilizes 106:6

UV 77:24

V

vac 72:13

vacuum 72:11

vacuumed 72:12

Valerie 2:24

37:22,25 115:11

valid 102:6

valuable 4:21 17:1

valves 24:10

varied 20:6

various 9:11

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versed 52:11

version 100:15,17

via 5:8

viable 65:23

vial 82:4

vice 52:6 53:23

108:25

view 45:17 113:6

viewing 5:25

views 26:14

vintage 26:5

violation 103:12

virgin 75:15

Virginia 2:3

21:17,18

virus 48:25

visual 107:3

visually 13:23 16:1

23:21

voice 86:14

volatile 67:22

volatilize 42:22

volume 72:19

voluminous 20:3

voluntarily 12:15

21:14

voluntary 11:15,21

12:7,16,25
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W

wafers 84:12

wake-up 62:22

walk 85:7

walked 92:8

wall 80:1 109:21

walls 58:10 110:21

warrant 37:8

warranted 20:12

wash 75:23

Washington 5:12

wasn't 53:2 54:14

64:1 76:6 81:3,7

82:11

waste 10:15 34:13

62:17 63:3,25

wastewater 101:14

watch 55:2 83:25

watching 58:8 59:7

63:17 64:3 99:10

water 59:11 63:7

67:22 68:4 70:24

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110:23

Waterbury 108:24

waterproofer 3:9

79:15

Watnick 2:24

37:22,23,25

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Watnick's 43:3

weakening 102:7

wear 37:25

weather 9:23 18:20

50:16

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101:5

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website 10:6 93:25

94:3

we'd 47:18

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week 43:22 46:21

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60:2

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weekly 55:8

weeks 50:17 52:23

weighed 84:13

weight 84:11

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Welcome 4:10 6:5

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we're 4:14 6:13

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west 4:14 21:17

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64:11 65:14 66:8

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wherever 58:10

whether 9:6 27:20

29:8 35:13 36:24

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73:13 95:4 96:25

98:16 100:3

101:17,19 105:16

106:18

whistle 82:17

whistleblower

81:10

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white-collar 99:17

whole 44:13 49:19

59:9 61:12 83:8

91:21 92:23

93:20 94:3,5

95:10,21 96:2,3

98:19

wholly 18:14

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widely 14:11 32:11

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92:4 97:6,13,24

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winterization

104:13 105:7

wipe 74:22,24

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wipes 56:9,16

withdraw 36:21

withdrawn 41:24

WITNESS 114:11

women 51:20,21

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wonder 58:4 90:4

wondering 108:9

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107:6 108:2,6

110:9

workday 87:22

worked 62:13

71:14 74:8,15,16

99:3

worker 86:22

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workmen 65:25

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Yorktown 71:23

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youngest 46:19

you've 72:1 78:10

87:16 94:7

Z

zero 78:6

Zicklin 2:25

zone 58:9

Zyrtec 50:9